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8
Protection from Retaliation
Policy Section 9.0
Step 1 of 7

ZERO-RETALIATION POLICY

No one will suffer any form of retaliation for submitting a report in good faith, whether anonymous or known.

9.2 What is Retaliation?

Any detrimental action taken because someone made a report:

  • Dismissal or demotion
  • Harassment or discrimination
  • Exclusion from meetings or projects
  • Any other negative action

Retaliation is itself misconduct and will be investigated.

Quick Check
After submitting a harassment report, Fatima notices her manager has excluded her from important team meetings and reassigned her best projects to someone else. She suspects this is connected to her report.
Is what Fatima is experiencing considered retaliation under the policy?

What To Do If You Experience Retaliation

9.3 Reporting Retaliation

  • File through the same platform
  • Investigated separately from original report
  • Can escalate to Chair of Board
  • Treated with same urgency as original

9.4 & 9.5 Rights & Legal

  • Accused can present their argument before action
  • Full compliance with whistleblower protection laws
  • Legal remedies available if retaliation occurs
Quick Check
Samuel experiences retaliation after his whistleblowing report. He is unsure how to report this second issue. His colleague suggests writing an email to the accused person's manager.
How should Samuel report the retaliation?

Legal Framework Protecting You

Kenyan Law

Kenya Data Protection Act and anti-corruption legislation

UN Convention

UN Convention Against Corruption (UNCAC)

OECD Standards

OECD Anti-Bribery Convention guidelines

AERC Policies

Code of Conduct and Safeguarding Policy

Your courage matters. AERC guarantees your protection when you report in good faith.
Final Check
Fatima has confirmed she is experiencing retaliation. She has documented the exclusion from meetings, project reassignment, and unfavorable reviews. She wants to take action.
What should Fatima do about the suspected retaliation?

Key Takeaways

  • Zero-retaliation policy — no one suffers any detrimental action for good-faith reports
  • Retaliation includes dismissal, demotion, harassment, exclusion, or any negative action linked to reporting
  • Report retaliation through the same platform — it is investigated separately and can be escalated to the Board Chair
Next up: Communication, Training & Compliance — final section!