Child Protection

1. Introduction

The work of Marine Conservation Philippines (MCP) is grounded in the United Nations Convention on the Rights of the Child (UNCRC) and its additional protocols. Under the UNCRC, everyone under the age of 18 is considered a child and is entitled to special protection and support. MCP works directly with school children through its environmental education programmes, and therefore places great importance on a clear, transparent, and actively implemented child protection policy.

This policy protects all children, with and without disabilities, in every area of MCP's work. MCP's task is to safeguard the rights of all children, support their development, and protect them from harm.

The best interests of the child and children's active participation are the two guiding principles behind MCP's work. This policy is further informed by the UN Convention on the Rights of Persons with Disabilities, the Universal Declaration of Human Rights, and ILO Convention No. 182 on the Worst Forms of Child Labour. Section 3 sets out the specific legal framework, including Philippine national law, that applies to MCP's work.

This Child Protection Policy is based on internationally recognised standards developed by ECPAT International and the Keeping Children Safe Coalition. In defining forms of sexual violence against and exploitation of children, this policy is guided by the Luxembourg Guidelines (Terminology Guidelines for the Protection of Children from Sexual Exploitation and Sexual Abuse, 2016).

2. Declaration of Commitment

With this Child Protection Policy, MCP ensures that child protection is a quality standard built into its own work, and that children of all genders, with and without disabilities, are supported in their rights and protected from sexual, emotional, and physical violence, exploitation, and neglect. MCP is committed to an environment that is safe for children, where children's rights are respected and observed. Children are involved, wherever appropriate, in decisions that affect them, and their views are given due weight.

This commitment is implemented and followed up through clearly defined responsibilities and procedures covering prevention, crisis management, and monitoring, set out in this policy. In its press, communications, and public relations work, MCP ensures that the dignity of the child is always respected and that the best interests of the child guide all of its educational work.

3. Legal and Regulatory Framework

MCP's child protection work operates within the following legal and regulatory framework:

International instruments

• United Nations Convention on the Rights of the Child (UNCRC) and its Optional Protocols
• UN Convention on the Rights of Persons with Disabilities (UNCRPD)
• Universal Declaration of Human Rights
• ILO Convention No. 182 concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour

Philippine national law

• Republic Act No. 7610, the Special Protection of Children Against Abuse, Exploitation and Discrimination Act
• Republic Act No. 11648 (2022), which raised the age of sexual consent to sixteen (16) and strengthened protections against statutory rape and sexual abuse
• Republic Act No. 11930 (2022), the Anti-Online Sexual Abuse or Exploitation of Children (OSAEC) and Anti-Child Sexual Abuse or Exploitation Materials (CSAEM) Act
• Republic Act No. 9775, the Anti-Child Pornography Act
• Republic Act No. 10173, the Data Privacy Act of 2012, which governs how MCP stores and handles personal data collected through its case management system
• Presidential Decree No. 603, the Child and Youth Welfare Code
• The role of the Barangay Council for the Protection of Children (BCPC) in the local child protection system

MCP's internal case management system, described in Section 6, operates alongside these legal obligations and does not replace or delay any report required by law to the appropriate government authority.

4. Scope

This policy and the accompanying Code of Conduct (Appendix A) apply to:

• All MCP staff, whether paid, volunteer, or contracted, including sea rangers, dive instructors, and researchers
• All members of the Executive Board and other MCP officials
• All divemaster trainees, interns, and researchers based with MCP
• Any school group, student, or child taking part in MCP's environmental education or outreach activities
• Partner organisations, contractors, boat operators, and homestay or accommodation providers engaged by MCP in contexts where children may be present
• Anyone representing MCP in an official capacity, whether in the Philippines or elsewhere

5. Elements of Preventive Measures

ACode of Conduct

All MCP staff tasked to work with children, board members, and partner organisation representatives involved in MCP's projects sign the Code of Conduct for Child Protection (Appendix A), committing to a protected environment for children. The Code sets a professional and personal child protection standard that applies both inside and outside the working environment.

BSafe Recruitment and Human Resources Standards

Preventive measures within personnel management are a key part of MCP's child protection approach. Child protection is addressed during recruitment for roles involving contact with children. Staff who teach children, or who may be alone with them, are required to provide a current NBI Clearance (for Philippine nationals) or an equivalent police clearance certificate from their country of residence (for foreign staff) before starting work. This requirement is explained clearly to all candidates. Volunteers and interns always work alongside MCP staff and are never left alone with children. Reference checks are conducted for all roles involving contact with children. Employees are also introduced to the Luxembourg Guidelines terminology for child sexual exploitation and abuse, so that appropriate, non-discriminatory language is used consistently in this area.

CTraining and Induction

All new staff are introduced to this policy in their first week and sign an acknowledgement. Staff who will work with children are also introduced to the Code of Conduct, and sign it, before beginning any work involving children. The Protection Officer keeps a record of who has completed this induction.

DProtection in Words and Images: Communication Standards

The dignity of the child, in any image or text used by MCP, is paramount. Reporting on MCP's education work is an important way to build awareness, but this kind of communication also carries a risk of violating children's rights. Words and images shape how children affected by sexualised violence and exploitation are perceived by society. In its press, education, and public relations work, MCP is committed to always respecting the dignity of the child and observes the following communication standards in any publication, including on its website or social media:

1. All media content is based on respect and equality and upholds the dignity of the person portrayed, especially children.
2. Children are portrayed as individuals with many facets and strengths; reducing a child to a victim or other stereotypical role is avoided.
3. MCP will not possess or publish photographs or images of an identifiable child that in any way depict, or could be interpreted as depicting, sexual exploitation.
4. Before creating media content, the children involved and their parents or legal guardians are informed of its purpose and use, and their consent is obtained.
5. Pseudonyms are used for children unless using a child's real name is in that child's best interest and both the child and their legal guardian consent.
6. Children are dressed appropriately, respecting the norms of their country and community; particular care is taken when creating or selecting images in settings where children wear minimal clothing, for example near water.
7. Descriptions of a child's living situation reflect their social, cultural, and economic context, to show the complexity of their circumstances rather than a simplified narrative.

EDigital and Online Safeguarding

MCP's education and outreach work increasingly involves digital communication and online publication, which carries its own risks. In addition to the standards above:

• Staff do not contact a child directly through personal social media accounts, messaging apps, or personal phone numbers, without the knowledge and consent of a parent or guardian.
• Photographs and videos of children taken for MCP's communications are handled according to the retention rules in Section 6.
• MCP does not livestream activities involving identifiable children without prior written consent from a parent or guardian.
• Any group chat or online communication involving children includes a parent, guardian, or another vetted adult from MCP.

6. Case Management System

MCP has an institutional system for handling and responding to suspected cases of child abuse. The case management system exists to ensure a prompt, appropriate response to concerns, to identify possible sexual violence or exploitation at an early stage, and to make sure affected children are protected and can access support to prevent further harm. It gives everyone at MCP a clear frame of reference and ensures information reaches the right people quickly. This system is known to all staff. The well-being and protection of the child is the basis of every decision made within it.

AProtection Officer

The Executive Board appoints a Protection Officer, who acts as the clear point of contact for all child protection matters and as MCP's internal and external complaints channel. Where a project involves a local community, a Protection Officer who speaks the local language is also appointed. The Protection Officer may be a board member or an external person appointed by the board. Implementation of this policy, including signature of the Code of Conduct, is monitored on an ongoing basis. In the event of a report or complaint, necessary measures are taken in consultation with management. Every report is taken seriously and followed up as a priority; the specific course of action depends on the circumstances of the case. The Protection Officer informs all Executive Board members of any incident or report as soon as possible, and no later than 48 hours after receiving it.

MCP's current Protection Officer is: Jason Matthews, jason@mcp.email

To ensure a report can always be handled appropriately, including in any case where the Protection Officer has a conflict of interest or is unavailable, MCP also appoints a Deputy Protection Officer: Magnus Midtjord, Director, magnus@mcp.email.

No one who raises a concern in good faith, whether about a colleague, a partner organisation, or any other person connected to MCP's work, will face any negative consequence for doing so, even if the concern is later not substantiated.

BNotification, Reporting, and Response to Suspicious Cases

A suspected case can come to MCP's attention in different ways. The next steps are clarified directly and confidentially with whoever raised the concern, or with others directly involved. This does not rule out involving other people where needed to clarify the situation; that decision rests with the Protection Officer, who may form a case-specific response team if necessary. Broadly, two situations can arise: a suspected case involving MCP staff or people in contact with children through MCP, and a suspected case involving staff of a partner organisation. Where MCP staff are involved, the Protection Officer decides immediately on next steps. Every report is processed quickly. How the case proceeds depends on how serious it is and how much information is available.

Whoever first receives a report should, before anything else:

• ensure the child's immediate safety;
• not investigate the concern personally or confront the person concerned;
• not promise the reporting person or the child unconditional confidentiality, since some information may need to be shared to protect the child;
• pass the report to the Protection Officer, or Deputy Protection Officer, within 24 hours.

CExternal Reporting

MCP's internal process runs alongside, and never instead of, its obligations under Philippine law. Where a report indicates a child may be at risk of serious harm, or where the law requires it, the Protection Officer notifies the appropriate external authority without delay. Appendix C lists the relevant external contacts for MCP's areas of operation.

DConfidentiality and Data Protection

Information gathered through the case management system is limited to what is necessary to protect the child and respond appropriately to the report. It is stored securely, with access restricted to the Protection Officer, Deputy Protection Officer, and Executive Board on a need-to-know basis, in line with the Data Privacy Act of 2012. Records are kept for at least ten years after a case is closed, or longer if a legal process requires it.

EConsequences of a Substantiated Concern

Where a concern is substantiated, MCP responds proportionately to what is found. This can range from additional training and supervision through to ending the individual's relationship with MCP and referral to law enforcement. The Executive Board decides on the appropriate response in consultation with the Protection Officer.

7. Documentation and Further Development

Transparency is maintained through proper documentation. Each case is documented according to predefined forms and filed appropriately; this is the responsibility of the Protection Officer, and supports MCP's ongoing internal learning to strengthen its child protection system. This policy is reviewed at least every two years, and additionally whenever triggered by a substantiated incident, a relevant change in Philippine law, or a significant change in MCP's programmes, such as a new school partnership or a new source of international volunteers or interns. Revisions take into account both MCP's own case experience and developments in internationally recognised child protection standards.

A. Appendix A: Code of Conduct for Child Protection

MCP's work is grounded in the United Nations Convention on the Rights of the Child (UNCRC) and its additional protocols. Under the UNCRC, everyone under the age of 18 is considered a child and is in particular need of protection and support. MCP is committed to the environmental education of school children and therefore attaches great importance to a goal-oriented, transparent child protection policy.

This policy protects all children, with and without disabilities, in every area of MCP's work. MCP's task is to strengthen the rights of all children, support their development, and protect them from potential harm. The best interests of the child and children's active participation are MCP's two guiding principles.

This Code of Conduct is further informed by the UN Convention on the Rights of Persons with Disabilities, the Universal Declaration of Human Rights, and ILO Convention No. 182 on the Worst Forms of Child Labour.

This Code of Conduct applies to:

• All professional and volunteer members of the MCP team
• All board members and other officials representing MCP
• All teachers and people working or travelling on behalf of MCP

Declaration of Commitment

I commit to:

• Respect all children as individuals, regardless of their background, gender, or sexual orientation, and to create and maintain an environment that is safe, nurturing, and encouraging for them.
• Never abuse the power or influence I have over the life and welfare of a child.
• Never engage in sexual, physical, or emotional violence against a child; specifically, I will never engage in a sexual act with or involving a child.
• Never ask a child for a favour that could be considered abusive or exploitative.
• Refrain from any form of threat, discrimination, physical or verbal abuse, intimidation, or unequal treatment.
• Follow this Code of Conduct when interacting with children in my private life, not only in my work for MCP.
• Respect MCP's Child Protection Policy on images of children, and only use images of identifiable children in MCP's publications where the child and their guardian have consented.
• Only contact a child directly online or by phone with the knowledge and consent of a parent or guardian, in line with MCP's Digital and Online Safeguarding standards.

I will:

• Fully respect and implement the Child Protection Policy in my work for MCP.
• Raise any concern, allegation, incident, or suspicion with MCP's Protection Officer.
• Behave in an exemplary manner towards children and vulnerable people, consistent with my position.
• Treat all children with respect and pay careful attention to how they respond to my behaviour.
• Follow the "two-adult rule": wherever possible, ensure another adult is present or within reach when working with children. Where individual conversations are necessary, I will tell another person in advance where and when this will happen.

I agree:

• To provide a current NBI Clearance, or an equivalent police clearance certificate from my country of residence, if I teach children or may be alone with them on behalf of MCP.
• That I have read and understood this Code of Conduct, and understand that MCP expects me to meet these standards at all times.

B. Appendix B: Form for Reporting Suspected Cases

The form for reporting a suspected case of child maltreatment or abuse is in the PDF version of this policy.

C. Appendix C: Emergency and External Reporting Contacts

The contacts below are checked at least once a year.

MCP Protection Officer

Jason Matthews, jason@mcp.email

MCP Deputy Protection Officer

Magnus Midtjord, magnus@mcp.email

DSWD, Negros Oriental Provincial Office

Landline: (035) 402-0115 or (035) 527-4678Mobile: 0927-704-5415Operating hours: Monday to Friday, 8:00 AM to 5:00 PM

PNP Women and Children Protection Desk (local station)

Messenger: https://www.facebook.com/messages/t/zamboanguitapolicestation0997-557-4057, Officer Cruz

Bantay Bata 163 (national child abuse hotline)

Email: bantaybata163@abs-cbnfoundation.comMessenger: https://www.facebook.com/bantaybata163PHHours: open 7 days a week from 7:00 AM to 7:00 PM (messages received outside these hours are addressed the next day)

Nearest hospital or medical facility

Refer to the Emergency Evacuation Plans posted around campus and in the windscreen of all MCP trucks.