Safeguarding, Zero Tolerance & Counter-Human Trafficking Policy Helpster
HELPSTER CHARITY US INC. 501(c)(3) Non-Profit Organization · EIN: 93-3969693 helpstercharity.org |
SAFEGUARDING, CHILD PROTECTION & ZERO TOLERANCE POLICY |
Document Title | Safeguarding, Child Protection & Zero Tolerance Policy |
Organization | Helpster Charity US Inc. |
Tax Status | IRS 501(c)(3) Public Charity | EIN: 93-3969693 |
Version | 1.0 |
Effective Date | July 2026 |
Next Review | July 2027 |
Policy Owner | Board of Directors |
Contact | team@helpstercharity.org |
Governing Law | Federal law of the United States of America; applicable state law |
1. PURPOSE & ORGANIZATIONAL COMMITMENT |
Helpster Charity US Inc. ("Helpster US" or the "Organization") is a U.S.-based 501(c)(3) public charity dedicated to ensuring that no child suffers or dies due to lack of financial means. Through our mobile platform and global network of verified volunteers, hospitals, and partners, we connect donors directly with children in developing countries who require life-saving medical treatment.
This Policy sets out the binding standards of conduct, reporting obligations, and response procedures that govern Helpster US and every individual or entity associated with our work. It reflects our unwavering commitment to:
■ protecting every child and vulnerable individual who comes into contact with our Organization;
■ operating with the highest standards of integrity, transparency, and financial accountability; and
■ maintaining zero tolerance for abuse, exploitation, harassment, human trafficking, fraud, bribery, and corruption of any kind.
This Policy applies globally — in the United States and in every country where Helpster US operates or funds activities.
2. SCOPE OF APPLICATION |
This Policy is binding on all "Covered Persons," defined as:
■ All employees, officers, and directors of Helpster US
■ Independent contractors, consultants, and advisors
■ Volunteers, interns, and fellows
■ Partner organizations, sub-grantees, hospitals, and vendors that receive Helpster US funding or access to beneficiary data
■ Program Visitors — any individual invited to observe, document, or participate in Helpster US activities
All Covered Persons are expected to comply with this Policy at all times — in both professional and personal contexts — 24 hours a day, 7 days a week, worldwide. Where a higher standard is required by applicable local or federal law, that higher standard shall apply.
3. KEY DEFINITIONS |
Child / Minor | Any individual under 18 years of age. Helpster US applies this definition globally, regardless of local age of consent. |
Vulnerable Adult | Any adult who may be less able to protect themselves from harm due to illness, disability, age, or circumstance. |
Safeguarding | The proactive and responsive measures taken by Helpster US to prevent, identify, and address harm to children and vulnerable adults arising from contact with our Organization. |
Harm | Physical, psychological, financial, or other damage caused to an individual through act or omission, whether intentional or negligent. |
Abuse | Any act or failure to act that directly or indirectly harms a person, including Physical Abuse, Emotional Abuse, Sexual Abuse, Neglect, and Exploitation. |
Sexual Exploitation & Abuse (SEA) | Any actual or attempted abuse of a position of trust or power for sexual purposes. All sexual activity involving a person under 18 is absolutely prohibited. |
Sexual Harassment | Unwelcome conduct of a sexual nature that creates an intimidating, hostile, degrading, or offensive environment. |
Human Trafficking | Recruitment, transport, transfer, or harboring of persons through coercion, deception, or force for the purpose of exploitation — including forced labor, sexual exploitation, or servitude. |
Fraud | Any intentional misrepresentation or deception intended to secure an improper financial or other gain, or to avoid an obligation. |
Bribery | Offering, giving, soliciting, or receiving anything of value to improperly influence a decision, award, or official action. |
Corruption | The misuse of entrusted authority or organizational position for personal or third-party gain. |
Designated Safeguarding Officer (DSO) | The individual appointed by the Board to serve as the primary point of contact for all safeguarding concerns and reports. |
Whistleblower | Any Covered Person who in good faith reports a concern, suspicion, or known violation of this Policy. |
Survivor-Centered Approach | An approach that places the dignity, safety, privacy, and informed choices of the survivor at the center of all organizational responses. |
4. GUIDING PRINCIPLES |
➤ Do No Harm: Helpster US will not expose any child or beneficiary to additional risk through our activities or the conduct of our Covered Persons.
➤ Best Interests of the Child: Every decision affecting a child must give primary weight to that child's welfare, safety, and long-term well-being.
➤ Survivor-Centered: The wishes, safety, and dignity of survivors are paramount in every safeguarding response. Survivors will never be pressured into participating in investigations.
➤ Universal Accountability: Every Covered Person — regardless of seniority or role — bears personal responsibility for upholding this Policy.
➤ Zero Tolerance: No form of abuse, exploitation, harassment, human trafficking, fraud, or corruption is acceptable. Every credible allegation will be investigated and acted upon.
➤ Non-Discrimination: Safeguarding protections apply equally to all individuals without regard to race, gender, age, nationality, religion, disability, sexual orientation, or any other characteristic.
➤ Confidentiality: All safeguarding information will be handled with strict confidentiality, shared only as required for investigation, legal compliance, or protection of individuals at risk.
➤ Whistleblower Protection: Covered Persons who report concerns in good faith are fully protected from retaliation.
5. PROHIBITED CONDUCT |
The following conduct is strictly and absolutely prohibited for all Covered Persons at all times. A violation of any item listed below constitutes a serious breach of this Policy and may constitute a federal or state criminal offense under applicable U.S. law.
5.1 Child Protection & Sexual Exploitation
■ Any sexual contact, activity, or relationship with a person under 18 years of age regardless of local age of consent, marital status, or any purported consent. Mistaken belief about age is not a defense.
■ Grooming any behavior designed to gain the trust of a child or their caregiver for the purpose of sexual exploitation.
■ Sexual exploitation of beneficiaries including the exchange of money, employment, goods, services, or charitable assistance for sex or sexual favors.
■ Producing, distributing, downloading, or possessing Child Sexual Abuse Material (CSAM) in any form, including digitally.
■ Deliberately exposing a child to sexual content, language, or conduct of any kind.
■ Entering into marriage or a comparable arrangement with a person under 18 years of age.
5.2 Physical, Emotional Abuse & Neglect
■ Any non-accidental physical force against any individual, including corporal punishment of children.
■ Verbal abuse, humiliation, threats, persistent shaming, or any conduct causing emotional harm.
■ Neglect of any child or dependent person under Helpster US's care or supervision.
■ Engaging individuals in harmful practices, including forced labor or dangerous activities.
5.3 Human Trafficking & Labor Exploitation
■ Recruiting, harboring, transporting, or obtaining any person for forced labor, sexual exploitation, or any form of trafficking.
■ Confiscating, concealing, or withholding any person's identity, travel, or immigration documents.
■ Using child labor in any form, including engaging children in activities harmful to their health, education, or development.
■ Making materially false representations to potential employees, volunteers, or beneficiaries regarding the terms of engagement, compensation, or work conditions.
5.4 Fraud, Bribery & Financial Misconduct
Helpster US has absolute zero tolerance for all forms of financial dishonesty. Donor funds are treated as a sacred trust. Every dollar collected goes directly to life-saving treatment for children. |
■ Fraud any intentional misrepresentation, falsification of records or beneficiary data, false expense reporting, or deception for financial gain.
■ Bribery offering, soliciting, or accepting anything of value to influence a decision, procurement process, or official action.
■ Embezzlement misappropriation of organizational funds, donations, assets, or equipment.
■ Corruption abuse of position or authority for personal gain, including undisclosed conflicts of interest.
■ Money Laundering concealing the origin of illegally obtained funds, or knowingly processing such funds.
■ Procurement Fraud bid manipulation, false invoicing, supply chain fraud, or creation of fictitious vendors.
■ Interference tampering with, destroying, or withholding evidence relevant to any investigation.
6. EXPECTED CONDUCT & SAFEGUARDING PRACTICES |
Beyond avoiding prohibited conduct, all Covered Persons are expected to actively contribute to a culture of safeguarding:
■ Read, understand, and comply with this Policy, and complete all mandatory safeguarding training.
■ Maintain clear, professional, and age-appropriate boundaries in all interactions with children and beneficiaries — in person and through digital channels.
■ Always identify yourself and your role clearly when conducting work on behalf of Helpster US.
■ Obtain and document explicit informed consent before photographing, filming, or otherwise recording children or beneficiaries.
■ Handle all personal and beneficiary data in accordance with applicable U.S. privacy laws and Helpster US's Privacy Policy.
■ Report concerns, suspicions, or known violations promptly — even when uncertain. When in doubt, report.
■ Cooperate fully and honestly in any investigation conducted under this Policy.
■ Disclose any actual or potential conflict of interest to the Board before taking any related action.
■ Support partners, hospitals, and volunteers in understanding and adhering to these standards.
6.1 Additional Responsibilities for Managers & Directors
■ Model exemplary safeguarding conduct and set clear expectations for those you supervise.
■ Ensure every new Covered Person receives and signs this Policy as part of their onboarding.
■ Foster an open environment where concerns are raised without fear of punishment or retaliation.
■ Include safeguarding performance expectations in evaluations and supervisory conversations.
■ Escalate all safeguarding concerns to the Designated Safeguarding Officer without delay.
7. SAFER RECRUITMENT |
Helpster US is committed to engaging only those individuals who are safe to work with children and vulnerable populations:
■ All candidates for roles involving direct or indirect access to children will undergo background checks and reference verification, including criminal history checks where permitted by applicable U.S. federal and state law.
■ Candidates will be directly questioned about prior safeguarding-related concerns, disciplinary findings, or criminal convictions involving abuse, exploitation, or financial misconduct.
■ All new Covered Persons must read and sign this Policy before commencing work.
■ Helpster US will verify the identity of all Covered Persons through official documentation.
■ Background check requirements will apply to international partners and field volunteers in accordance with the laws of their respective jurisdictions.
8. REPORTING OBLIGATIONS & PROCEDURE |
Any Covered Person, beneficiary, donor, or member of the public who witnesses, learns of, or reasonably suspects a violation of this Policy is obligated to report it immediately. Reports may be made anonymously.
8.1 How to Report
REPORT A CONCERN — HELPSTER US SAFEGUARDING CONTACTS Confidential E-mail: team@helpstercharity.org Website: https://helpstercharity.org Anonymous reports are accepted and will be acted upon. Mandatory External Reporting: Where an allegation involves immediate risk to a child, Covered Persons must also report to local law enforcement and/or child protective services (CPS) in the relevant jurisdiction, in compliance with applicable mandatory reporting laws. |
8.2 Reporting Timelines
■ All concerns must be reported to the DSO within 24 hours of becoming aware of the issue.
■ The DSO will acknowledge receipt of every report within 48 hours.
■ Concerns involving immediate risk to a child must be escalated to law enforcement immediately.
■ Concerns involving potential IRS violations, financial fraud, or misuse of charitable funds may also be reported to the relevant state Attorney General's office or the IRS.
8.3 Confidentiality of Reports
All reports and related information will be treated with the highest level of confidentiality, shared strictly on a need-to-know basis. The identity of any reporter will not be disclosed without their explicit consent, except where disclosure is required by law or essential to protect a person at risk.
9. INVESTIGATION PROCEDURE |
Every report received under this Policy will be taken seriously and reviewed in a prompt, fair, and impartial manner.
Step 1 — Initial Triage (within 48 hours)
The DSO assesses whether the report constitutes a credible concern requiring investigation, immediate referral to law enforcement, or corrective management action.
Step 2 — Protective Measures
Where a Covered Person is named in a credible allegation, immediate protective measures will be implemented pending investigation — which may include suspension of access to children, reassignment, or administrative leave — without implying a presumption of guilt.
Step 3 — Formal Investigation
A thorough internal investigation will be conducted by the DSO or an independent investigator designated by the Board, observing principles of impartiality, due process, and confidentiality for all parties.
Step 4 — Law Enforcement Referral
Where alleged conduct may constitute a criminal offense under U.S. federal or state law, Helpster US will refer the matter to the appropriate law enforcement agency and cooperate fully.
Step 5 — Documented Outcome
A clear, written outcome will be recorded for every investigation, regardless of whether the Covered Person remains associated with Helpster US at the time of conclusion.
Step 6 — Disciplinary Action & Remediation
Covered Persons found to have violated this Policy will face consequences including, where appropriate, termination, legal action, recovery of misappropriated funds, and referral to law enforcement.
If a Covered Person resigns or is terminated during an investigation, the investigation will nonetheless proceed to a documented conclusion.
10. SURVIVOR SUPPORT & ASSISTANCE |
Helpster US places the safety and dignity of survivors at the center of all responses to safeguarding concerns:
■ Survivors retain full autonomy over whether to participate in any investigation.
■ With the survivor's informed consent, Helpster US will facilitate referrals to medical, psychological, legal, and other appropriate support services.
■ Support will be provided regardless of whether an investigation has been initiated or concluded.
■ Survivor privacy will be protected at all stages of any reporting or investigation process.
■ Helpster US will cover reasonable emergency support costs for beneficiaries directly harmed by the conduct of a Covered Person.
11. ZERO TOLERANCE FOR FRAUD & FINANCIAL MISCONDUCT |
As a 501(c)(3) public charity, Helpster US operates as a steward of public trust. Every donation is accepted with a commitment that it will be used exclusively for the charitable purpose of funding life-saving medical treatment for children in need. Misuse of donor funds is a betrayal of that trust and may constitute a violation of federal and state law.
11.1 Financial Controls & Prevention
■ Dual authorization is required for all financial transactions exceeding applicable thresholds established by the Board.
■ The Board of Directors conducts annual reviews of internal financial controls and audit procedures.
■ All Covered Persons with financial responsibilities must complete financial ethics and fraud prevention training.
■ Covered Persons must promptly disclose any actual or potential conflicts of interest to the Board.
■ Helpster US maintains accurate books and records in compliance with federal and state nonprofit accounting standards.
11.2 Reporting Financial Misconduct
Report Financial Misconduct: Confidential E-mail: team@helpstercharity.org Direct Escalation: Board of Directors Chairperson External: IRS (Form 13909) / State Attorney General (Charitable Trust Division) All reports will be investigated. Anonymous reports are accepted. |
11.3 Consequences for Financial Misconduct
■ Immediate termination of employment or engagement.
■ Civil action by Helpster US to recover any misappropriated funds or assets.
■ Referral to the IRS, FBI, state law enforcement, or other applicable federal and state agencies.
■ Disclosure to donors, regulators, and enforcement agencies as required by law or donor agreements.
12. WHISTLEBLOWER PROTECTION & NON-RETALIATION |
Helpster US strictly prohibits any retaliation against any Covered Person who, in good faith, reports a concern, provides information, or participates in an investigation under this Policy.
Retaliation includes — but is not limited to — dismissal, demotion, exclusion, intimidation, harassment, reduction in responsibilities, or any other adverse action taken because a person made a good-faith report.
Whistleblower protections are provided under multiple applicable U.S. laws, including the Sarbanes-Oxley Act of 2002 (SOX), 18 U.S.C. § 1513, applicable state whistleblower statutes, and the terms of any federal grant or contract. Helpster US maintains a formal Whistleblower Protection Policy consistent with these obligations.
A Covered Person who believes they have been subjected to retaliation must report this to the Board Chairperson immediately at team@helpstercharity.org. Knowingly making a false report is itself a breach of this Policy and may result in disciplinary action.
13. DIGITAL SAFEGUARDING & ONLINE SAFETY |
Helpster US operates primarily through a digital platform (the Helpster App). Digital safeguarding is therefore a critical operational priority. All Covered Persons must:
■ Use only Helpster US's official channels and accounts when communicating with beneficiaries, hospitals, or volunteers.
■ Never contact children directly through personal social media, messaging applications, or personal email.
■ Obtain explicit documented consent before photographing, recording, or sharing images or personal information of children.
■ Never share images or identifying information of children on personal social media or any non-official platform.
■ Store and process beneficiary personal data in compliance with applicable U.S. privacy law (including COPPA, CCPA where applicable) and Helpster US's Privacy Policy.
■ Report any suspicious or inappropriate online communications involving children to the DSO immediately.
14. PARTNER, HOSPITAL & VENDOR OBLIGATIONS |
All partner organizations, hospitals, sub-grantees, and vendors engaged by Helpster US must maintain safeguarding and anti-fraud standards equivalent to those set out in this Policy:
■ Partners must confirm their safeguarding commitments as a condition of entering into any agreement with Helpster US.
■ Helpster US will conduct risk-based due diligence on all partners prior to engagement.
■ Partners who receive Helpster US funds or beneficiary data must comply with applicable data protection requirements.
■ Partners must report any safeguarding concern involving their personnel to Helpster US's DSO in accordance with this Policy.
■ Breach of safeguarding obligations or failure to maintain equivalent standards may result in suspension or immediate termination of the partnership agreement and may render the partner ineligible for future engagement.
15. TRAINING & AWARENESS |
■ All Covered Persons will complete safeguarding induction training prior to or immediately upon commencing their engagement with Helpster US.
■ Annual refresher training is mandatory for all Covered Persons.
■ The Designated Safeguarding Officer will complete specialist-level safeguarding and child protection training.
■ Training completion records will be maintained by Helpster US.
■ This Policy is publicly available on the Helpster US website (helpstercharity.org).
16. GOVERNANCE & ACCOUNTABILITY |
16.1 Designated Safeguarding Officer (DSO)
The Board of Directors will appoint a Designated Safeguarding Officer responsible for:
■ Receiving, logging, and responding to all safeguarding reports.
■ Overseeing investigations and ensuring timely, appropriate action.
■ Maintaining a confidential register of all safeguarding concerns and outcomes.
■ Reporting regularly to the Board of Directors on safeguarding matters.
■ Serving as the primary liaison with law enforcement and regulatory authorities.
■ Ensuring this Policy is current, implemented, and communicated to all Covered Persons.
16.2 Board of Directors
The Board of Directors bears ultimate fiduciary and legal accountability for Helpster US's safeguarding obligations. The Board will:
■ Formally approve this Policy and all material amendments.
■ Receive regular safeguarding reports from the DSO.
■ Ensure adequate resources and capacity for safeguarding implementation.
■ Take all required corrective, legal, and disciplinary action following any investigation finding.
■ Ensure compliance with all IRS, state nonprofit, and federal grant reporting obligations.
17. APPLICABLE U.S. LEGAL & REGULATORY FRAMEWORK |
This Policy is informed by and designed to ensure compliance with the following legal instruments and regulatory standards:
Child Protection
■ Protect Act of 2003 (18 U.S.C. § 2256 et seq.) — Child Sexual Exploitation and Abuse
■ Child Abuse Prevention and Treatment Act (CAPTA), as amended
■ Trafficking Victims Protection Act (TVPA), 22 U.S.C. § 7101 et seq.
■ U.S. PROTECT Act and IMBRA (International Marriage Broker Regulation Act)
■ State mandatory reporting laws (applicable in each state of operation)
Anti-Trafficking & Labor
■ Trafficking Victims Protection Reauthorization Act (TVPRA)
■ Fair Labor Standards Act (FLSA) — Child Labor Provisions
■ U.S. Forced Labor Enforcement Act
Financial Integrity & Nonprofit Law
■ Internal Revenue Code § 501(c)(3) — Tax-Exempt Status & Charitable Purpose
■ False Claims Act, 31 U.S.C. § 3729 et seq.
■ Foreign Corrupt Practices Act (FCPA), 15 U.S.C. § 78dd et seq.
■ Sarbanes-Oxley Act (SOX) — Whistleblower Protections, 18 U.S.C. §§ 1513, 1514A
■ State nonprofit corporation law and charitable registration requirements
■ USAID ADS 303 Mandatory Standards (where applicable to federal funding)
Privacy & Data
■ Children's Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq.
■ California Consumer Privacy Act (CCPA) — where applicable
International Standards
■ UN Convention on the Rights of the Child (UNCRC), 1989
■ UN Protocol to Prevent Trafficking in Persons (Palermo Protocol), 2000
■ IASC Six Core Principles Relating to Sexual Exploitation and Abuse
■ UNICEF Policy on Safeguarding, June 2025 (reference standard)
18. POLICY REVIEW & AMENDMENT |
This Policy will be reviewed and updated at least annually by the Board of Directors, or more frequently upon any material change in Helpster US's operations, applicable law, or safeguarding best practice. All Covered Persons will be notified of material amendments and may be required to re-acknowledge updated versions.
Version | Effective Date | Notes |
1.0 | July 2026 | Initial adoption — U.S. entity version |
Helpster Charity US Inc. · 501(c)(3) · EIN: 93-3969693 · helpstercharity.org · team@helpstercharity.org