Introduction
EF High School Exchange Year is committed to providing a safe, meaningful, and enriching experience for our participants. As a youth serving organization, we are responsible for upholding a code of conduct and child protection policy to protect the safety of our students.
All part-time and full-time staff, local coordinators, host family members, chaperones, contractors, and volunteers associated with EF High School Exchange Year must adhere to this Code of Conduct and Student Protection Policy.
Definitions
Abuse: Any act or failure to act that results in harm or the risk of harm to another person’s physical, sexual, emotional, or psychological well-being.
Adult: A person aged 18+
Child neglect: The failure to meet a minor’s basic needs.
Child protection: Individual, institutional, and societal measures to protect the health, well-being, and human rights of minors to live free from abuse, harm, and neglect.
Child sexual abuse: Any sexual contact, conduct, or exploitation between an adult and a minor, or between two minors when one exerts power over the other. Child sexual abuse takes many forms and does not require physical contact.
Code of Conduct: Document that outlines the actions a group will take to protect children at a particular institution.
Commercial exploitation: Range of crimes and activities involving the sexual abuse or exploitation of a child for the financial benefit of any person or in exchange for anything of value (including monetary and non-monetary benefits) given or received by any person.
Consent: Consent is a freely given, informed, and ongoing agreement to engage in sexual activity. It can be withdrawn at any time. Consent cannot be given by individuals who are underage, intoxicated, under the influence of drugs, asleep or unconscious, or in unequal power dynamics.
Gaslighting: Manipulative distortion of the truth to make a victim doubt their own memory or perception of reality.
Grooming: A deliberate process by which offenders build trust with a minor (and often those around the minor) in order to create opportunities for abuse or exploitation. Grooming behaviors may appear as special attention, friendship, or mentorship, and often occur openly before boundaries are progressively violated. Grooming is itself a form of abuse and is prohibited under this policy.
Harassment: Harassment is unwanted conduct including a single severe act or a pattern of behavior directed at a person that creates an intimidating, hostile, or distressing environment.
Mandated Reporter: A person who, because of their profession or position, is legally required to report any suspicion of child abuse or neglect to the relevant authorities. The official designation of which professions are considered mandated reporters varies from state to state. EF HSEY considers all individuals who have direct contact with students, including employees, IECs, and volunteers, as mandated reporters.
Minor: Minor is legally defined in most states as a person under the age of 18. While 18-year-old students are legal adults, EF HSEY applies the same protective standards to all program participants.
Person in position of authority or trust: Anyone who, because of their role, relationship, or access through the program, has supervisory, evaluative, caretaking, disciplinary, instruction, transport, housing, decision making, or special access to students. This could also apply for a person under 18 but acting in authority.
Student: Student refers to EF HSEY exchange students, however, the same conduct is expected towards all minors.
Facts of Child Sexual Abuse
*Darkness to Light, a non-profit committed to empowering adults to prevent child sexual abuse.
One in ten children will be the victim of sexual abuse before their 18th birthday.
93% of abused children know, and perhaps even greatly trust, their abuser.
Child sexual abuse thrives in an environment of denial and fear.
The sexual abuse of a child often has lasting negative consequences for the child, the child’s family, and community.
Childhood sexual abuse is never the fault of the child.
EF High School Exchange Year Zero-Tolerance Policy
EF High School Exchange Year has a zero-tolerance policy for any type of inappropriate behaviors, sexual abuse, physical abuse, neglect, emotional maltreatment or harassment toward our students or other minors. Any suspected child abuse and/or neglect concerns will be immediately reported to the appropriate authorities. Any inappropriate communication or inappropriate behaviors are prohibited and will result in dismissal/termination and/or involvement of the authorities.
Code of Conduct
It is the responsibility of adults to set and protect appropriate boundaries with minors. Acknowledging the existence of child sexual abuse, sexual harassment, and grooming behaviors helps to actively identify situations that could foster an abusive situation during a student’s program year and take immediate steps to promote student safety.
Communication
EF High School Exchange Year requires healthy, safe, and respectful communication with students, both verbally and electronically.
Healthy communication is:
Respectful and supportive.
Trustworthy.
Positive and builds self-esteem.
Age appropriate and bounded, respecting the adult-minor dynamic.
Prohibited communication is:
Sexually suggestive or vulgar such as:
Commenting on a student’s body or appearance inappropriately.
Discussing sex, sexual experiences, or sexual relationships.
Making sexually provocative jokes.
Using profanity as degrading, sexual, or threatening language.
Emotionally inappropriate such as:
Excessively texting a minor or doing so late at night.
Discussing intimacies of marriage or adult relationships.
Using flirtatious communication.
Discriminatory or harassing such as:
Engaging in bullying, humiliation, or harassment of any kind.
Engaging in discriminatory comments, exclusions, or undertones.
Making jokes about race, ethnicity, gender, or sexuality, or disabilities.
Manipulative such as:
Grooming behaviors that test boundaries.
Requesting a student to keep secrets from trusted adults or EF.
Using disappearing messages or private apps to communicate.
Isolating a student from forming healthy relationships with peers.
Abusing authority or trust.
Using gaslighting to minimize a student’s concerns or feelings.
Threatening control over a student’s program participation and/or immigration status.
Behavior
EF High School Exchange Year requires healthy, safe, and respectful behavior towards students and that appropriate boundaries are always maintained.
Healthy behaviors are:
Respectful of privacy such as:
Students must have uninterrupted privacy for sleeping, dressing, and using the bathroom.
Students must not share a bed with adults, even while traveling.
Any use of a surveillance device, including cameras or audio recording equipment, must be disclosed to a student prior to arrival and immediately upon installation. Use of cameras or other surveillance devices in a student’s bedroom or bathrooms is prohibited.
Respectful of safety such as:
Students have the right to say “no” regarding their body, safety, or comfort.
Students must have unimpeded access to contact EF HSEY or their parents. Phones may not be confiscated as punishment.
Prohibited behaviors include:
Inappropriate Physical Behaviors such as:
Kissing, wrestling, tickling, or massaging a student, or unwanted hugging.
Touching a student sexually in any way or touching any personal area, including patting the buttocks or placing a hand on their thigh.
Physically interacting with a student in any way that makes them feel uncomfortable.
Being intoxicated in front of a student and/or driving a student while under the influence.
Being not fully dressed in common areas of the home.
Providing illegal materials such as:
Providing drugs or alcohol to student.
Showing a student pornography or other images containing nudity or leaving these images out in the open where a student could reasonably see them.
Disrespecting privacy such as:
Walking in on a student unannounced or without consent in their bathroom or bedroom.
Film or photograph a student inappropriately or without their consent.
Use surveillance cameras in private rooms such as the bathroom or student bedroom and/or use surveillance cameras without the student’s knowledge.
Manipulation such as:
Giving gifts or money that are exclusive, excessive, or private, or those that are done to show favor.
Abuse of any kind such as:
Physical abuse, corporal abuse, verbal abuse, sexual abuse, mental abuse, or neglect.
Electronic Communication and Social Media
EF High School Exchange Year requires healthy, safe, and respectful communication with students, both verbally and electronically.
Healthy electronic communication is:
Observable and appropriate for a professional relationship.
Prohibited electronic communication includes:
Use of disappearing messages, such as on messaging apps
Engaging with students on social media platforms in ways that could be perceived as intrusive, romantic, or inappropriate.
Posting discriminatory messaging that is fundamentally misaligned with EF’s core values celebrating diversity and inclusion.
Taking, posting, or distributing sexually explicit or inappropriate images of students is inappropriate and is illegal.
Personal Boundaries
EF High School Exchange Year expects that students’ personal boundaries are respected. Students come from diverse cultural backgrounds. Understanding and respect should be applied in topics including, but not limited to:
Firearms: EF HSEY strongly discourages exchange student participation in activities that involve the use of firearms or other such weapons due to the inherent associated risks and dangers. In the limited circumstances where a student and their parents request such participation against EF HSEY’s recommendation, the student’s legal parents or guardians must sign a liability waiver prior to participation.
Culture around firearms may be different in the US than in a student’s home country. Use, culture, and beliefs of firearms may also vary between regions of the US, family beliefs, and individual beliefs. EF HSEY expects that any individual who participates in firearm-related activities or possession follows all appropriate safety measures and abides by local, state, and federal laws .
Household discipline: Discipline in the home varies widely based on cultural and individual practices. Any discipline must be proportionate, respectful, and consistent with EF HSEY policies. A student’s program or visa status should never be used as a threat of discipline. EF HSEY does not condone corporal punishment of exchange students under any circumstances. Host families are also expected to ensure that exchange students are not placed in environments where they witness or are exposed to physical discipline of other household members in a manner that creates fear, distress, or an unsafe atmosphere.
Teenage independence: Students may come from countries where teenagers are extended greater independence than in typical US households. Host families should communicate expectations (for example regarding curfews, transportation needs, and permission for activities) clearly and respectfully.
Politics: Politics should not be discussed in a way that is mocking or dismissive of the student’s political views, their home countries, or others.
Religion: Students come from different backgrounds and faiths. The exchange visitor cannot be required to participate in religious practices and/or services, but may decide to experience this facet of U.S. culture at their discretion.
Responding to Concerns
Responding Procedure
At EF High School Exchange Year, it is imperative that we work to create an environment where students feel confident coming forward if they feel unsafe or uncomfortable.
How we respond to concerns of abuse or other inappropriate behaviors can have a lasting impact on the student.
Healthy and supportive response includes:
Open-ended questions.
Empathy: “I’m so sorry this happened to you.”
Praise: “I’m so proud of you for telling me,” or “you are so brave for telling me.”
Belief: “I believe you. This is not your fault.”
Reassurance: “It’s ok to be scared/sad/mad.”
Support: “I am here for you.”
Transparency: “We are going to talk to specialists who keep students safe.”
Unhealthy and unsupportive response includes:
Denial: Stating or implying the incident didn’t happen.
Blame: Stating or implying the student may be to blame.
Question validity of concerns: Stating or implying that the student’s feelings or facts aren’t true.
Over-protect the student or emphasize the student as a victim.
Respond overly emotionally.
Excessive questions or investigating the facts:
The authorities will do the investigation.
Many questions can be unnecessarily upsetting for the student and affect later professional investigation.
Responding to disclosures in non-supportive, shaming, or accusatory manner could result in an end of affiliation with EF HSEY.
Removing the student from harm’s way
If there is a concern for a student’s safety or well-being, EF High School Exchange Year will take all reasonable and immediate steps to help protect the student, which may include immediately removing the student from any potentially unsafe environment. Our student safety motto is to “act first, ask questions later.” At EF HSEY we have escalation and reporting policies to quickly bring the student into a safe environment and to immediately involve the authorities.
Removal of a student from a host family placement is a provisional safety measure and does not constitute a finding of wrongdoing. All placements may be suspended or terminated at EF HSEY’s discretion when student safety is at risk.
Reporting Procedure
EF High School Exchange Year has a zero-tolerance policy for any type of sexual abuse, physical abuse, neglect, emotional maltreatment or harassment toward student participants or other minors, and we immediately report concerns to the appropriate authorities. EF HSEY will report any allegations of inappropriate behavior involving any minor, regardless of whether the minor is a program participant.
EF HSEY staff must immediately report any suspicion of abuse or neglect of a minor to the appropriate local authorities and/or child protective services and to EF HSEY. Staff are not required to confirm, investigate, or substantiate abuse before reporting. If you have any reason to suspect abuse or neglect, report it. The investigation is the responsibility of authorities, not EF HSEY personnel.
IECs must immediately report any suspected abuse or neglect of a minor to EF HSEY staff. If that is not practicable, IECs must make a report directly to the local authorities or child protective services.
Once the report has been filed, further investigation into the concerns will be conducted by the authorities and other experts in this field. A report will also be filed with the US Department of State, as they oversee J1 high school exchange programs.
File a Report
EF High School Exchange Year expects students, parents, host families, coordinators, and
staff to immediately raise any concerns of inappropriate communication or inappropriate behavior by:
Emergency services
911
Immediate danger
EF High School Exchange Year
1-800-447-4273
Safety or wellbeing concerns
BridgeUSA, US Department of State
866-283-9090
Reporting abuse or exploitation of an exchange student
Prevention
Training & Education
EF High School Exchange Year provides information on the topic of child sexual abuse prevention and response. We believe that knowledge is the first step in prevention.
Training for Students
According to the US Department of State Regulations for high school exchange programs, “all sponsors must provide exchange students, prior to their departure from their home countries...age and language appropriate information on how to identify and report sexual abuse or exploitation.”
It is imperative that students feel confident coming forward if they have any concerns and know that at EF High School Exchange Year, student safety comes first. Students receive information on how to identify and report sexual abuse or exploitation as part of their pre-departure and in country orientation materials.
In our safety trainings, students learn what are appropriate vs inappropriate interactions, grooming behaviors, and reporting concerns. Students learn that they are encouraged to come forward with any concerns, that they will be listened to, and that they will never be in trouble for coming forward.
Students and their families receive EF HSEY’s Comprehensive Code of Conduct and Student Protection Policy and Safety Notice to Students.
Training for Staff
All EF High School Exchange Year staff who have direct contact and communication with students will receive annual training on child sexual abuse prevention and EF HSEY’s prevention policies and procedures.
The Program Support Team specializes in student support and is in communication with students throughout their exchange. This team receives extensive training on child sexual abuse prevention and crisis response annually.
Information for International Exchange Coordinators (IECs)
As the local representatives and local support to students and host families during the exchange, IECs receive information on how to recognize, prevent, and report child sexual abuse at the time of their engagement and annually thereafter. IECs are also required to agree to EF High School Exchange Year’s Comprehensive Student Protection Policy and Code of Conduct as part of their annual contract renewal.
Information for Host Families
While caring for students in their home, host families have an important responsibility towards child protection. Host families receive information on how to recognize, prevent, and report child sexual abuse at the time of their onboarding and annually thereafter. Host families are also required to acknowledge and agree to EF High School Exchange Year’s Comprehensive Student Protection Policy and Code of Conduct annually.
Hiring, Screening & Contracting Practices
Staff, host families, and IECs undergo a screening process prior to onboarding or contracting and during annual renewal. Screening includes, but is not limited to, annual criminal background checks, references, and interviews. Criminal background checks include sex offender registry checks and are conducted through a nationally recognized third-party provider. All adults (17+) residing in the host home are subject to screening. EF HSEY reserves the right to determine disqualifying criteria at its sole discretion
All families and local coordinators must agree to EF High School Exchange Year Comprehensive Student Protection Policy and Code of Conduct.
Host families are required to notify EF HSEY of any new household members that join the home at any time prior to or during the exchange so that they can be screened and have a background check conducted.
Monitoring for Protection
EF High School Exchange Year regularly monitors participants through at least one scheduled in-person visit per semester as well as periodic in-home visits.
IECs maintain ongoing communication with students and host families and provide monthly safety checks and recorded documentation of this communication to EF HSEY. These updates are reviewed by the Program Support Team to assess student safety, wellness, and overall program satisfaction.
The EF High School Exchange Year Program Support Team conduct student surveys throughout the year to assess student safety, wellness, and overall program satisfaction.
Students are provided and encouraged to contact emergency contacts, should they ever feel unsafe or uncomfortable on exchange.
Emergency services
911
Immediate danger
EF High School Exchange Year
1-800-447-4273
Safety or wellbeing concerns
BridgeUSA, US Department of State
866-283-9090
Reporting abuse or exploitation of an exchange student
Consequences of Policy Violations
Any violation will be thoroughly reviewed and could result in:
Official warnings and updated vetting and training requirements
Dismissal/termination and/or separation from the program
Reporting to and full cooperation with the authorities and/or Child Protective Services
Reporting to and full cooperation with the US Department of State
Commitment
Review Process & Improvement
EF HSEY is committed to the prevention of child sexual abuse. EF HSEY will continually review our policies, procedures, screening, and support to help ensure safe and healthy experience for program participants.
Safety Notice to Students
Student safety comes first.
It is never ok for anyone to make you feel unsafe or uncomfortable. If they do, notify someone right away. You are never alone.
EF High School Exchange Year is available 24 hours a day, 7 days a week
at 1-800-447-4273.
People I can call for help:
My parent/guardian
A trusted adult: An adult, at home or in the US, who has your best interest at heart
Emergency services in the US (911): Dialing 911 connects you to emergency support of the police, fire department, and ambulances
EF High School Exchange Year (1-800-447-4273): A member of our staff Program Support team is available 24 hours a day, 7 days a week.
US Department of State, BridgeUSA (1-866-283-9090): The US Department of State oversees high school exchange.
My host family
My International Exchange Coordinator (IEC): Your International Exchange Coordinator (IEC) is your local support. They will check in with you and your host family every month for your Exchange Updates, will visit you in person, and are there to support you on exchange.
My Regional Coordinator (RC): Your Regional Coordinator works with all the International Exchange Coordinators in your greater area. They are another layer of support for you.
Grooming
Grooming is an inappropriate, deliberate process by which an offender builds trust in order to create opportunities for abuse. Grooming often feels like special attention, friendship, or mentorship at first, but then slowly pushes boundaries towards the inappropriate. It can happen in both co-ed and same gender dynamics.
Report any concerns of inappropriate boundaries right away.
You will not get in trouble for reporting concerns.
You will not lose your program participation or your visa.
You will be believed.
Inappropriate Communication: It is inappropriate or illegal for an adult to communicate with you this way.
Sexually suggestive: Discussing sex, sexual experiences, or sexual relationships. Making sexually provocative jokes. Commenting on your body inappropriately.
Emotionally inappropriate: Texting you excessively or late at night, discussing their marriage problems, using flirtatious language
Manipulative: Asking you to keep secrets from trusted adults or EF, using disappearing messages to communicate, isolating you from healthy relationships with peers, telling you “No one will believe you,” or threatening your program participation or visa.
Inappropriate behavior: It is inappropriate or illegal for an adult to interact with you this way.
Inappropriate physical behavior: Kissing, wrestling, tickling, or massaging you, unwanted hugging, touching you sexually in any way or in private areas of your body, or not being fully dressed in your presence. You have the right to say “no” regarding your body, safety, or comfort.
Providing illegal materials: Providing you drugs or alcohol, showing you pornography or sexual images.
Disrespecting privacy: Walking in on you unannounced in your bedroom or bathroom. You must never share a bed with an adult.
Manipulative: Giving you excessive or lavish gifts for your cooperation.
Abusive: Physical, corporal, verbal, sexual, mental abuse or neglect
Your safety matters.
EF High School Exchange Year is available to help you 24 hours a day, 7 days a week.