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This policy (the “Policy”) describes Vietnam Children’s Fund Social Enterprise Company Limited (“VCF SE”)’s commitment to protecting children and the safety of minors in every possible way. The Policy’s purpose is to ensure that children – who are served by VCF SE programs are safe from all forms of abuse/molestation, risk of, or actual harm from VCF SE Employees, Guests, and/or Representatives across all programs, operations, campaigns, or activities at any place or at any time. 


This Policy applies to all VCF SE’s Guests, Employees, and Representatives at all times and locations, including activities considered to be outside the VCF SE’s sphere of influence. In particular:

Guest (1)

This includes any non-employee or non-representative of VCF SE who is invited by VCF SE to participate in programs or attend an event or activity conducted or sponsored by VCF SE.

Employees and Representatives

This includes Employees, Volunteers, Interns, Consultants, Board members, Partners, and others who work with children on VCF SE’s behalf, visit VCF SE’s programs, or access the Sensitive Personal Data of children in VCF SE’s programs.



A person under 18 years of age (2)

The Rights of Child/Children’s Rights

  1. The right to be alive
  2. The right to be registered at birth and to have nationality
  3. The right to healthcare
  4. The right to be cared for and nurtured
  5. The right to education, learning, and talent development
  6. The right to play and recreation
  7. The right to preserve and develop identity
  8. The right to freedom of belief and religion
  9. The right to property
  10. The right to privacy 
  11. The right to live with parents
  12. The right to reunification, contact, and communication with parents
  13. The right to alternative care and to be adopted
  14. The right to be protected from sexual abuse
  15. The right to be protected from labor exploitation
  16. The right to be protected from violence, abandonment, and neglect
  17. The right to be protected from trafficking, kidnapping, fraudulent exchange, and appropriation
  18. The right to be protected from drugs
  19. The right to be protected during legal proceedings and handling of administrative violations
  20. The right to be protected when facing natural disasters, catastrophes, environmental pollution, and armed conflicts
  21. The right to be guaranteed with social welfare
  22. The right to access information and engage in social activities
  23. The right to express opinions and assemble
  24. The rights of children with disabilities
  25. The rights of stateless children, refugee children, and displaced children

Child Protection (3)

Child Protection refers to the implementation of suitable measures ensuring the safety, health, and holistic well-being of children, as well as preventing, addressing, and remedying instances of child abuse and exploitation; and providing support to children facing special circumstances.

Child Welfare Policy

Child Welfare Policy refers to the regulations and policies implemented to safeguard the welfare of children, fostering a community where children thrive in terms of physical and mental health, happiness, and safety. They encompass complaints regarding child abuse that may occur outside the scope of VCF SE and/or are mandated by local laws or regulations to be reported to the relevant local government authority. Such complaints may involve allegations of child abuse and exploitation by families, societal entities, or organizations.

Prohibited Acts

Prohibited Acts refer to all behaviors that violate Children’s Rights as stipulated herein, including but not limited to:

  1. Depriving children’s right to life.
  2. Abandoning, neglecting, trafficking, kidnapping, fraudulently exchanging or appropriating children.
  3. Sexual assault, violence, abuse, or exploitation of children.
  4. Organizing, supporting, inciting, or forcing children into underage marriage.
  5. Employing, enticing, inciting, provoking, taking advantage of, dragging, seducing or forcing children to commit illegal acts or hurt the honor or dignity of other people.
  6. Obstructing children from exercising their rights and duties.
  7. Declining to provide, or covering up, hindering the provision of, information on children being abused or children at risk of exploitation or violence to their families, educational institutions, agencies, or competent persons.
  8. Committing bias or discrimination against children due to their personal characteristics, family circumstances, gender, ethnicity, nationality, beliefs, and religion.
  9. Selling to children or letting children use alcohol, beer, cigarettes and other illegal addictive substances or stimulants and food that is unsafe and harmful to children.
  10. Providing Internet and other services; producing, duplicating, circulating, operating, spreading, owning, transporting, storing, and trading in publications, toys, games, and other products serving children with content affecting their healthy development.
  11. Announcing or disclosing information on children’s personal lives or secrets without the consent of a seven-year-old or older child and their parents or legal guardians.
  12. Taking unfair advantage of alternative care to abuse children, taking unfair advantage of the State’s regimes and policies, and the support and assistance of organizations and individuals for children for self-seeking purposes.
  13. Locating service establishments, production facilities, or goods warehouses that cause environmental pollution or hazards or have a direct risk of fire or explosion near child protection service establishments, educational institutions, medical or cultural establishments, or playgrounds for children, or vice versa.
  14. Occupying or using infrastructure facilities reserved for children’s learning, play, and recreation activities or child protection services for improper purposes or violating the law.
  15. Refusing to provide, failing to provide, or inadequately and untimely providing assistance, intervention, or treatment for a child who is at risk or in danger of physical harm, honor, and dignity.

Sensitive Personal Data (4)

Sensitive Personal Data refers to personal data intimately associated with an individual’s privacy rights which, when being infringed, will directly affect an individual’s legitimate rights and interests, including:

  1. Political opinions, religious beliefs;
  2. Health status and personal life reflected in medical records, excluding blood type information;
  3. Information related to racial or ethnic origin;
  4. Information about genetic data related to an individual’s inherited or acquired genetic characteristics;
  5. Information about an individual’s biometric or biological characteristics;
  6. Information regarding the sexual life and sexual orientation of the individual;
  7. Data on crimes and criminal activities collected and stored by law enforcement authorities;
  8. information on customers of credit institutions, foreign bank branches, intermediary payment service providers, and other permitted organizations, including customer identification as prescribed by law, accounts, deposits, deposited assets, transactions, organizations, individuals acting as guarantors at credit institutions, bank branches, intermediary payment service providers;
  9. Data on the individual’s location identified through location-based services;
  10. Other personal data specified by law as sensitive and requiring necessary security measures.

Child Abuse (5)

Child Abuse refers to actions undertaken or not undertaken directly or indirectly by individuals, organizations, or processes that cause harm to children or compromise their prospects for safe and healthy development into adulthood. This can include physical, emotional, and psychological dignity and moral harm to children through the form of, including but not limited to, violence, exploitation, sexual abuse, trafficking, abandonment, neglect, and other forms of harm.

Child Sexual Abuse (6)

Child Sexual Abuse refers to the act of using violence, threatening to use violence, forcing, persuading, or seducing a child to engage in sexual acts, including rape, aggravated rape, sexual intercourse, and lewdness with a child and using children for prostitution and pornography purposes in any form.

Child Sexual Abuse is not limited to physical contact, but includes all forms of violence and coercion or threat of using force, sexual solicitation, manipulation, or using tactics to engage a child in sexual acts, including incest, forced child marriage, rape, participation in or exposure to indecent images/videos (also known as pornography), sexual slavery/human trafficking and rape, aggravated rape, lewdness with children, and other crimes as prescribed by law. Child Sexual Abuse may include, but is not limited to, groping, indecent touching, or contact, sexually explicit language toward children, and “Child Sexual Grooming.” Child Sexual Abuse is not limited to physical contact.

Child Sexual Exploitation

Child Sexual Exploitation refers to any abusive act, whether actually committed or in the form of attempted abuse, against a person in a vulnerable position who is dependent on power or special trust for the purpose of sexual exploitation, including but not limited to obtaining financial gain, social, or political status advantages from the sexual exploitation of victims. It is important to be aware that technology is sometimes used as a tool to exploit and sexually abuse children. The exploitation and sexual abuse of individuals under 18 years of age not only constitutes child abuse and exploitation, but also violates the codes of conduct. Depending on the age of majority, local law, and customs, these acts may also constitute criminal offenses.

Lewdness With A Child (7)

‘Lewdness With A Child’ refers to a sexual act of individuals, regardless of gender, who engage in direct or indirect physical contact through clothing with the genitalia, sensitive areas, or other parts of a child’s body, but not for the purpose of sexual intercourse, including one or more of the following actions:

  1. Using genitalia or sensitive parts to make contact (e.g., touching, rubbing, friction) with the genitalia, sensitive areas, or other parts of a child’s body;
  2. Using other parts of the body (e.g., hands, feet, mouth, tongue, etc) to make contact (e.g., stroking, touching, squeezing, pinching, kissing, licking) with the genitalia, sensitive areas of a child;
  3. Using sexual objects to make contact (e.g., touching, rubbing, friction, etc) with the genitalia, sensitive areas of a child;
  4. Coercing or forcing children to use other parts of their bodies to make contact (e.g., stroking, touching, squeezing, pinching, kissing, licking, etc) with the sensitive parts of the offender or others;
  5. Other sexually suggestive behaviors not aimed at sexual intercourse (e.g., kissing on the mouth, neck, ears, nape of the child).

Child Pornography (8)

Child Pornography refers to an act of using gestures, actions, verbal expressions, written words, symbols, images, or sounds intended to arouse the sexual desire of children; exposing genitalia, sensitive areas, nudity, striptease, or performing simulations of sexual activities (including intercourse, masturbation, and other sexual behaviors) in any form.

Child Neglect/ Negligent Treatment (9)

Child Neglect/Negligent Treatment refers to an act of parents, caregivers, or guardians failing to fulfill their duties and responsibilities in caring for and nurturing children. This includes, but is not limited to, not providing enough food, clothing, and/or suitable shelter according to seasonal needs; failing to prevent harm; lacking adequate supervision; failing to ensure access to appropriate healthcare services or providing inappropriate medical treatment methods (e.g., using the medication without proper authorization); or failing to provide a safe environment (e.g., exposure to violence, unsafe in design or arrangement of location or sleeping space, handing over a child to unauthorized adolescents, access to weapons or harmful objects/items, lack or absence of actions to create a safe environment or objects for children, minimizing all risks including potential risks within a space where children will utilize, play, or engage in activities, etc.).

Child Exploitation (10)

Child Exploitation refers to an act of forcing a child to work against the law on labor; performing or producing pornographic products; organizing or supporting tourism activities for the purpose of child sexual abuse; offering, adopting, or supplying children for prostitution activities, and other behaviors of using the child for a profiteering purpose.

These infringements may occur in actuality or attempted form against a person in a vulnerable position, who is dependent on power or special trust for the purpose of personal gain in terms of status, power, privilege, or wealth by exploiters (through coercion, manipulation, force, or deception) to hire children for labor, turn them into domestic servants, force them to commit crimes, participate in armed combat, or undergo organ transplants or forced organ removal. Typically, Child Exploitation aims for financial gain, social status, or political influence. Such exploitation may occur with one or a group of children within the community where they live or beyond, even on an international scale. Child Exploitation may include but is not limited to:

  • Slavery;
  • Forced labor;
  • Pickpocketing, begging, drug transportation, drug production, or smuggling;
  • Being used as tools for fraudulent schemes;
  • Being forced to join gangs or criminal organizations and
  • Other similar exploitative behaviors.
Child Sexual Grooming


Child Sexual Grooming refers to a process in which an adult builds a relationship (performs “predatory” behavior) with a child or the child’s caretaker to gain their trust for the purposes of child sexual abuse and/or exploitation. “Grooming” typically occurs in phases, and it can happen online or face to face, by a stranger, or by someone the child or caretaker knows. Since it is a gradual process, it can sometimes be challenging to detect. Here are a few indicators that an adult may be grooming a child or their caretaker: 

  • Favoring the child (the target child of the “grooming” process) over others.
  • Providing the child with rewards or privileges. 
  • Isolating or separating the child from others. 
  • Expressing care for a particularly vulnerable child or in need of support (e.g., a child who has been previously abused). 
  • Befriending the parents or caretakers who are responsible for protecting and caring for the child.
  • Providing the child with alcohol or prohibited drugs or narcotics. 
  • Building intimacy (i.e., having inside jokes or stories that only the victim and the groomer understand, or telling the child that nobody understands them as well as “the groomer”/perpetrator does).
  • Threatening, blackmailing, intimidating, or scaring a child by saying “the groomer” will do something to the child’s family or friends.
Child Emotional Abuse (12)

Child Emotional Abuse refers to any form of abuse that is the root cause of negative impacts, causing harm to the psychological development, dignity, and integrity of children. It may include but is not limited to bullying, insulting honor and dignity, isolation, expulsion, abandonment, neglect, control, grooming, or befriending for the purpose of sexual exploitation, Child Sexual Grooming, blackmail, verbal and/or psychological threats, or berating children, as well as other deliberate behaviors causing mental harm to children.

Child Physical Abuse

Child Physical Abuse refers to the use of physical force in a manner that is not accidental or incidental, but rather deliberate or unintentional, resulting in actual physical harm or potential harm to children. Physical impacts include but are not limited to acts of abuse, maltreatment, beating, bodily harm, injury, hitting, shaking, kicking, twisting, pushing/pulling, grabbing, burning, cutting female genitalia for non-medical reasons (13), torture, and other acts of physical violence. Physical injuries or harm may include but are not limited to bruises, scars, soft tissue swelling, hematoma, fractures, sprains, dislocations, burns, organ damage, death, permanent disfigurement, and any other significant physical injuries or harm.


  1. VCF SE is committed to providing a safe environment for children by ensuring all VCF SE’s Guests, Employees, and Representatives adhere to high standards of conduct and implement policies and procedures to prevent and respond to any Prohibited Acts.
  2. VCF SE strictly prohibits all our Guests, Employees, and Representatives from performing any Prohibited Acts as outlined in this Policy or any other acts prohibited by law.
  3. All Guests, Employees, and Representatives of VCF SE must strictly observe and fully comply with laws on child protection and Child Welfare Policy, including but not limited to Law No. 102/2016/QH13 – Children Law 2016 and the United Nations Convention on the Rights of the Child. (14)
  4. VCF SE’s Guests, Employees, and Representatives who jointly implement projects must implement measures to eliminate Prohibited Acts committed by themselves or others. Examples of such measures include limiting unsupervised interaction with children, prohibiting children’s exposure to pornography, or restricting being alone with children.
  5. VCF SE does not tolerate any unauthorized (illegal) participation in matters involving children’s involvement on social networks, whether the parties involved are affiliated with VCF SE or not. Any children featured in VCF SE’s campaigns, events, communications, or fundraising activities will be identified only by the child’s name and place of residence (province level); contact details, the child’s family name, or location will not be disclosed. VCF SE’s Guests, Employees, and Representatives must comply with VCF SE’s policies, applicable laws, and regulations regarding the photography or filming of children. Ensure VCF SE’s Guests, Employees, and Representatives always have permission from the child’s parents or legal guardians to take photos/videos or use or disclose data about children in the future.
  6. Strictly comply with regulations on children’s personal data protection.


  1. All VCF SE’s Guests, Employees, and Representatives are required to notify or report to the management, human resources department, and CEO of VCF SE immediately about any violations or suspected violations of this Policy. Within three working days from receipt of the notice or denunciation, the parties will meet to determine the validity of the notice or denunciation and the following handling roadmap if the notice or denunciation is valid. Remedial measures will be taken immediately by the highest level of management. All information, notices, and denunciations during the process of receiving, verifying, or exchanging information for the protection of children must be kept confidential for the benefit and safety of the information provider and the benefit of the involved children. 
  2. All VCF SE’s Guests, Employees, and Representatives are required to notify the National Child Protection Hotline; or Labor, War Invalids, and Social authorities at all levels; police authorities at all levels; or the commune-level People’s Committees to ensure the safety of children or prevent future harm if any party believes that there has been any violation of the law. Immediate intervention is required, regardless of whether the violator is affiliated with VCF SE or not.
  3. VCF SE will investigate and clarify all reports of suspicion of any Prohibited Acts and take appropriate remedial measures, including, but not limited to, announcing to the National Child Protection Hotline; or Labor, War Invalids, and Social authorities at all levels; police authorities at all levels; or the local People’s Committee and cooperating with the investigation and prosecution of crimes.
  4. VCF SE strictly prohibits retaliation against any VCF SE’s Guests, Employees, and Representatives reporting suspicion of Prohibited Acts under this Policy. VCF SE’s Guests, Employees, and Representatives who engage in any form of retaliation against whistleblowers suspected of Prohibited Acts under this Policy will be held accountable for such acts and be subject to appropriate remedial action, up to and including reporting the violation to law enforcement, terminating the employment relationship, or terminating any other working relationship in the future with VCF SE or applying all of the above methods at the same time.
  5. VCF SE’s Guests, Employees, and Representatives who commit Prohibited Acts or fail to report suspected Prohibited Acts under this Policy may be subject to appropriate disciplinary measures, up to and including the immediate termination of the employment relationship or the termination of any future engagement with VCF SE.
  6. VCF SE will make every effort within our means to ensure that all VCF SE’s Guests, Employees, and Representatives have no history of Prohibited Acts. Suppose a person is found to have any history of the behavior mentioned above; in that case, this is grounds for termination of any past, present, or future relationship with VCF SE.
  7. Allegations must be truthful and not contain personal revenge. After being investigated and clarified, any acts of abuse or intentional defamation will be subject to disciplinary measures corresponding to the nature and extent of damage to the victim’s reputation, up to and including, but not limited to, termination of the employment contract or termination of any future association with VCF SE and other legal consequences, if any.

This Policy was reviewed and approved by the CEO of Vietnam Children’s Fund Social Enterprise Company Limited.

(1) Once the Guests agree to confirm participation in our programs in any form, it means they have fully acknowledged all content and committed to adhering to this policy, which has been publicly posted and published, including but not limited to on our website.

(2) According to the United Nations Convention on the Rights of the Child on November 20, 1989, by the United Nations General Assembly. Vietnam ratified it on February 20, 1990.

(3) Clause 1, Article 4 of the Law on Children 2016

(4) Article 2.4 Decree 13/2023/ND-CP

(5) Article 4.5 Children’s Law 2016.

(6) Clause 8, Article 4 of the Law on Children 2016

(7) Article 3.3 Resolution 06/2019/NQ-HDTP

(8) Article 3.4 Resolution 06/2019/NQ-HDTP

(9) Clause 9, Article 4 of the Law on Children 2016

(10) Clause 7, Article 4 of the Law on Children 2016

(11) A person who undertakes childcare duties including but not limited to parents, respite care recipients.

(12) Clause 6, Article 4 of the Law on Children 2016

(13) Female genital mutilation (FGM)

(14) United Nations Convention on the Rights of the Child is one of the regulations that fully regulates the children’s rights and is an international human rights treaty that is widely ratified and applied around the world

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