Corporate report

Safeguarding against sexual exploitation, abuse and harassment: cross-sector progress report 2022 to 2023

Published 30 January 2024

Introduction

It has now been 5 years since the UK hosted the 2018 London Summit on tackling sexual exploitation and abuse and sexual harassment (SEAH) in the international aid sector. The Summit convened stakeholders including representatives from the United Nations (UN), UK non-governmental organisations (NGOs), International Financial Institutions (IFIs), the UK private sector, the Global Fund and GAVI, research funders, CDC Group (now British Investment International), British Red Cross and donors representing 90% of global Official Development Assistance (ODA) at the time of the summit. Each of these stakeholder groups made a set of commitments in line with 4 strategic shifts that framed the Summit’s work:

• ensure support for survivors, victims and whistle-blowers, enhance accountability and transparency, strengthen reporting and tackle impunity
• incentivise cultural change through strong leadership, organisational accountability and better human resource processes
• agree minimum standards and ensure we and our partners meet them
• strengthen organisational capacity and capability across the international aid sector, including building the capability of implementing partners to meet the minimum standards

The UK’s Foreign, Commonwealth and Development Office (FCDO) convenes and chairs a Cross-Sector Safeguarding Steering Group (CSSG) which consists of representatives from all stakeholders who made Summit commitments, alongside independent voices, the CHS Alliance and the Steering Committee for Humanitarian Response (SCHR). Since 2018 the CSSG has met quarterly as a forum to share progress, challenges and examples of best practice across the sector. In the spirit of accountability, transparency and learning the CSSG prepares an annual progress report to update on work to prevent and respond to SEAH in line with the London Summit commitments. This is the fifth annual progress report and also offers a 5-year retrospective. Previous progress reports are on GOV.UK. 5 years on from the London Summit good progress continues to be made, but many challenges remain and much more work is needed to improve the response to SEAH and to tackle complex and wide-ranging issues that enable it to occur in the first place.

Summary

In the last 5 years, since 2018, progress has been made by all members of the CSSG across the humanitarian, development and peacekeeping sectors. There has been continued commitment by all members to implement safeguarding policies and principles, an increase in dedicated training and substantial growth in communities of practice on protection from sexual exploitation, abuse and harassment (PSEAH). Challenges remain in reporting, collecting and sharing incidence data for many organisations and sectors. Ensuring accountability of perpetrators and justice for victims-survivors is also a long-term challenge that remains, alongside technical and financial resource constraints. The CSSG has served as a valuable forum for representatives across the sector to discuss progress, challenges and lessons learnt so we can collectively improve our prevention and response efforts to SEAH and continue to support victims, survivors, and whistle-blowers.

Highlights and trends

Growth of communities of practice on SEAH

• since 2018 a range of Communities of Practice in the aid sector have been created. IFIs have strengthened their collaboration through regular meetings of an IFI SEAH Working Group. Respective approaches to SEAH are shared through this platform, including risk screening and grievance management, and increasing staff capacity building. A joint multilateral development bank (MDB) website portal for sharing SEAH-related resources has been launched, including a series of educational short videos, to strengthen MDB collective approaches

• bilateral donors engage in a specific donor safeguarding investigation group (DOSIG) to deal with challenges and opportunities to improve SEAH investigations, as well as being highly active in wider communities of practice. These CoPs include donors working with: their own national NGO groups on standards and due diligence; the Inter-Agency Standing Committee (IASC) to follow up on the 2021 IASC External Review of PSEA (PDF, 4.8 MB) recommendations; the Core Humanitarian Standard Alliance (CHSA) SEAH CoP through peer learning and use of new guidance to support implementation of the SEAH elements of the Core Humanitarian Standard (CHS) through the PSEAH Index and e-learning

Increased alignment of minimum standards across and between organisations

• in the last 5 years donors have made significant progress in adopting minimum standards and strengthening language in formal funding agreements with partners to reflect minimum language and standards on SEAH. Fifteen UN Member States and 11 UN agencies agreed to harmonised SEAH language in 2021 that is aligned with international standards and has created greater alignment between donors

• increased alignment is also evident within the UN system as PSEAH has been embedded across UN operations. Heads of UN entities at headquarters and in country offices are now required to submit annual action plans identifying risks of SEA and mitigation measures and mandatory training for all personnel on the prevention of SEA. System-wide policies and frameworks have also been developed to prevent sexual harassment. The Chief Executives Board (CEB) Task Force on Addressing Sexual Harassment works across UN System entities and has developed a uniform system-wide model policy on sexual harassment to align the policies of UN organisations, as well as a harmonised mechanism for system-wide collection and analysis of data; a common guide for managers to prevent and respond to sexual harassment

Continued commitment to the implementation of safeguarding policies and principles

• many organisations have significantly expanded and strengthened PSEAH policies, procedures and training in the last 5 years. Gavi has updated its Respectful Behaviour Policy and rolled out training for the Gavi workforce (including staff, consultants and interns). UK research funders have continued to demonstrate commitment to raising safeguarding standards through efforts such as developing, and publishing relevant safeguarding policies or reviewing existing guidance. The National Institute for Health and Care Research (NIHR) is currently updating their Safeguarding Policy. It sets out the standard NIHR approach to safeguarding and provides guidance for those involved in managing NIHR programmes

• in line with the growing emphasis on addressing SEAH within organisations, IFIs have undertaken reviews of their codes of conduct and whistleblower policies to create a more enabling environment and organisational culture to effectively address SEAH issues. Promoting psychological safety and ensuring that staff can speak up remains a priority for IFIs. In collaboration with external partners, many IFIs have expanded their approaches to preventing and addressing sexual harassment at work

Incidence data, reporting and sharing of SEAH information remains a key challenge for many CSSG members

• donors agree that in the last 5 years, data on SEAH has remained a significant problem and many efforts have been focussed on addressing this. The CHSA data harmonisation pilot is designed to increase transparency and reduce underreporting, through the development of a harmonised SEAH data framework, that is aligned with the UN I-Report. Project Soteria, with INTERPOL aims to improve sharing of criminal information within and across borders to prevent perpetrators from moving around the aid sector. An increasing number of donors now proactively encourage their partners to use the Misconduct Disclosure Scheme, that facilitates sharing of misconduct data between employers

• research funders, including Wellcome have engaged in discussions around data protection and sharing of SEAH information and overcoming barriers to ensure that organisations can address this sector-wide challenge. Gavi also faces challenges in reporting SEAH incidents in Gavi-supported countries as the organisation is typically removed from direct involvement in the delivery of vaccines to recipients in countries. This makes it more difficult to inform victims and witnesses of SEAH about Gavi’s reporting channels and commitment to providing support to victims

Ensuring accountability of perpetrators and justice for victims and survivors remains an ongoing challenge

• the UN continues to refer credible allegations of SEA against UN officials and experts on mission to their States of nationality. Some minor progress in resolving paternity and child support claims has been made. However, pursuing alleged fathers across jurisdictions is time-consuming, as victims lack access to legal assistance and legal processes to realise these claims are complex

• there is still a lack of awareness and capacity among IFI staff and clients in understanding and applying a survivor-centred approach. The lack of, or low capacity of, GBV services such as health, psychosocial, protection, legal, and livelihood for victims and survivors, hampers survivor-centred responses to SEA/SH incidents

Resource constraints

• resourcing gaps (both financial and technical) compound other challenges and make it hard to deliver accountability for survivors and protect the integrity of overall work. In a reducing-aid environment these challenges require significant political leadership, support and commitment across the system

• UK NGO network, Bond, shared that time dedicated to safeguarding is a long-term challenge for many organisations. Safeguarding responsibilities are often added as an additional role to an existing staff post. Competing priorities might mean less time is dedicated to safeguarding

• some Research Funders also report that they have been constrained in their ability to make significant progress on PSEAH – and report on it. The primary challenge in undertaking further work in this area is resource constraints

Next steps

Donors will continue to collaborate in various fora to exchange and test ideas, address challenges and pursue joint initiatives to drive up standards and accountability across all areas of summit commitments. Focusing on how to support a more unified and coherent international architecture, that is appropriately and sustainably resourced, will be a focus for many.

An important milestone is the launch of the online public consultation of the Common Approach to protection from SEAH (CAPSEAH). It brings together actions on SEAH safeguarding from existing practice, policies and standards into a simple guide for everyone contributing to Humanitarian, Development and Peacekeeping work with the aim of improving alignment of approaches to SEAH safeguarding across countries, organisations and programmes. CSSG members have played a critical role in the development of the CAPSEAH and will continue to do as international cross-sector stakeholders look to agree the Common Approach in 2024.

IFIs will provide more guidance and mandatory training programs, strengthen reporting systems, and develop psychological safety initiatives and a talent pool of trained consultants to assist projects in addressing SEA/H risks. Some IFIs are also considering creating dedicated SEAH-specific technical staff positions. All IFIs will continue their efforts to better coordinate, harmonise, and align their approaches to SEAH across their respective operations.

The UN IASC will focus on deployment of dedicated PSEA Coordinators to SEA high risk contexts to support humanitarian leadership through the PSEA Capacity project. The UN Office of the Victims’ Rights Advocate (OVRA) will continue to devote significant resources to advocacy for the resolution of outstanding paternity/child maintenance claims, and as part of that intends to focus on providing early legal assistance to victims and their children. The UN Office of the Special Coordinator on sexual exploitation and abuse (OSCSEA) will focus on enhanced communication within the UN system to ensure a clear understanding of the prohibition against SEA and the consequences for violators, to foster a culture change, to promote accountability, and to cultivate an environment free from sexual exploitation and abuse across the organisation.

BII will provide proactive support to sectors where there is an assessment of elevated safeguarding risk based on data and incidents to date. This will enable specific sectors, investment products and power dynamics that are higher risk to be identified and mitigated.

Donors

The 2018 Summit commitments accelerated donor efforts on Protection against sexual exploitation and abuse and sexual harassment (PSEAH) in the aid sector. The 22 commitments by 23 donors (478 KB) focus on making improvements around 4 strategic sets of issues as set out in that document. Quarterly meetings of the donor SEAH technical working group (TWG) and annual progress reports have driven progress.  The commitments were built into the 2019 DAC Recommendation on Ending SEAH and so delivery is also helped by the work of the DAC SEAH Reference Group and related monitoring.

Progress

Since 2018 this has included (numbers with a # refer to the commitment number out of the 22): setting or improving policy, procedures and training (#20) for staff and partners; leadership and governance initiatives such as senior level champions and annual discussions (#7 and 8); increased staffing levels including the establishment of some dedicated safeguarding units; strengthened due diligence processes, employment and referencing procedures (#10, #15); new behavioural codes; new case management and investigations teams (#1); and much more extensive international coordination and collaboration. The latter has been done in various ways: bilaterally; through the TWG and the DAC Reference Group and other fora such as United Nations meetings; and between donors and others many of whom have contributed to this report. 5 examples follow:

1. Common approach to protection from SEAH (CAPSEAH)

Whilst political commitments have been made (eg Tidewater, UK Summit, OECD DAC Recommendation, G7 2018, 2021 (PDF, 583 KB) and 2023 (PDF, 503 KB)), ongoing challenges, discussed for example at the June 2023 Wilton Park conference, set in motion a collaborative process to agree to a common approach that would address the need to drive coherence, galvanise political momentum and advocate for sustainable resourcing to effect long-term change. TWG members, including Australia, Canada, EU UK, USA actively engaged, with the whole spectrum of summit partners engaged, to take this forward, along with many others who made commitments in 2018 or have an interest in safeguarding.

2. The 2018 commitment to adopt minimum standards

The 2018 commitment to adopt minimum standards included the proposition to strengthen formal funding agreements with partners to reflect minimum standards and language on SEAH (#15). In 2021, 15 UN Member States^{[footnote 1]} agreed harmonised SEAH language, alignment with international SEAH standards and reporting procedures with the UN Office of Legal Affairs, covering selected agencies’ funding agreements^{[footnote 2]}.  The arrangement is reducing time spent negotiating SEAH procedures in agreements.  Lessons are that negotiations to establish initial agreement take time to enable mutual understanding of expectations and space for legal quality assurance. A similar approach between donors and the Multilateral Finance Institutions (MFIs) has been proposed. 9 donor MFI shareholders^{[footnote 3]} approached 11 MFIs^{[footnote 4]} (August 2023) proposing a similar approach for trust fund financing agreements with clients.

3. The OECD DAC recommendation on ending SEAH, 2019

The OECD DAC Recommendation on Ending SEAH, 2019 (#17) is the only international instrument to address SEA and sexual harassment together and to require action across development cooperation and humanitarian assistance. The SEAH Reference Group remains an important forum for peer learning, identifying SEAH challenges and supporting member states and others to implement the Recommendation. A SEAH toolkit was developed and will be published in 2024; the 5-year monitoring survey is underway, with the report on progress across all DAC member states over the last 5 years due in early 2024 will identify future priority actions.

4. SEAH evidence and best practice

Knowledge is a public good when shared freely and accessibly, delivering the possibility of more effective policies and operational practice that will benefit many. Donors continue to support efforts to generate and broker research and evidence to do just that on SEAH. Examples include, the UK Safeguarding Resource and Support Hub, Digna (Canada), Empowered Aid (USA), with a new Australian initiative, the GBV Prevention Platform in Southeast Asia, to be inaugurated in May 2024. Actively sharing research and evidence helps generate more good practice, new ideas and learning and problem solving on intractable problems. Communities of practice are critical to this endeavour.

5. Communities of practice on SEAH

The impetus from 2018 stimulated a variety of Communities of Practice. The DAC Reference Group and donor TWG are referenced above. Bilateral donors also engage in a smaller donor safeguarding investigation group (DOSIG) to deal specifically with challenges and opportunities to improve SEAH investigations, as well as being highly active in wider communities of practice. These CoPs included donors working with: their own national NGO groups on standards and due diligence; the IASC to follow up on the 2021 IASC External Review of PSEA (4.8 MB) recommendations; the Core Humanitarian Standard Alliance (CHSA) SEAH CoP with peer learning between PSEAH experts of CHS members and the use of new resources and guidance to support  implementation of the SEAH requirements of the CHS through the PSEAH Index and its e-learning; and with each other through collective action at the UN Chief Executives Board (CEB) to support the Secretary General’s 2017 Special Measures to tackle SEA.

Community of practice on employment accountability

The USAID and Netherlands Ministry of Foreign Affairs launched a Community of Practice on Employment Accountability (2020), comprised of donors, academics, NGOs and aid practitioners (231 participants) with a particular focus on preventing the hiring and recirculation of perpetrators in the aid sector (#3). Building on efforts from the 2018 Summit and the 2019 OECD DAC Recommendation on Ending SEAH, an Employment Accountability Roadmap resulted, focusing on capacity building, human resources, investigations, legal affairs and risk management. Conversations continue through the DAC PSEAH Reference Group.

These communities continue to be important entities to unpack and address continuing challenges, bringing together international, national and local representation and expertise.

Challenges and lessons

1. The Summit commitment to review and strengthen due diligence tools

The Summit commitment to review and strengthen due diligence tools (#15) through reflecting commitments to international standards (#14) has greatly progressed over the last 5 years with many donors updating their requirements to reflect the IASC Minimum Operating Standards (MOS-PSEA) and/or the PSEAH requirements of the Core Humanitarian Standard (CHS). This also includes the IASC 6 Principles on SEAH in codes of conduct for staff and partners; and aligns with the DAC Recommendation on Ending SEAH. Some donors are pursuing alignment through their reference of CHS verification for their funding processes (Denmark, Germany, Dutch Relief Alliance, Ireland; and the UK Disaster Emergency Committee members have adopted the CHS as part of the DEC accountability framework).

Meanwhile, several donors have gone further, collaborating to explore the potential to ‘passport’ or substitute elements of their own due diligence processes with HQAI’s independent CHS audit. Passporting could help improve quality and accountability whilst reducing the burden for donors and partners. This is a challenging ambition that the UK, Luxembourg, Switzerland, Germany and Denmark are continuing to support, with some promising results noted in the following case study.

Case study: Testing the potential to bridge donor due diligence and HQAI CHS certification audits: Bangladesh (#14 and #15)

HQAI is testing the use of CHS audits as a common approach to harmonising due diligence requirements. HQAI auditors completed a due diligence audit of a national NGO in Bangladesh which aimed to cover the due diligence requirements of HQAI CHS and 4 donors EU/ECHO, Denmark/DANIDA, Luxembourg and the UK/FCDO). The audit was able to cover about 80% of the due diligence requirements for all organisations through meeting the certification standard requirement for the CHS, and was able to include additional questions required to bridge the remaining 20% to the other due diligence frameworks. The pilot findings support the premise that the CHS, as a common audit framework, conducted to independent standards, could support organisations to meet more than one organisation’s due diligence requirements, and if accepted by donors, could support the direction of travel towards a more harmonised, high quality and less duplicative system. Participating donors continue to explore the potential for formally using this approach. The multi-year process of HQAI’s CHS audits also lends itself to building the capability of participating organisations over time, from those who initially self-certify to those reaching higher certification standards. The audit process also engages with communities at field level, lending quality assurance engagement with aid beneficiaries.

2. Incidence data, reporting and sharing of information

Incidence data, reporting and sharing of information (#2; #4) remains a significant problem, undermining the ability to understand the nature and magnitude of SEAH, the potential to support victims/survivors (#5), the ability to hold perpetrators to account (#3, #10) and undermines evidence-based policy development. The CHS Alliance SEAH data harmonisation Scheme (#2) is designed to increase accountability and transparency, and to reduce underreporting, through the development of a harmonised SEAH data framework, that is aligned as much as possible with the UN I-Report. Donors are encouraged to promote its use with their partners, during the scale-up phase starting in October 2023; and to align with the data sets in reporting their own data publicly. Project Soteria, with INTERPOL aims to improve sharing of criminal information within and across borders, including between law enforcement agencies, to prevent perpetrators from moving around the aid sector. An increasing number of donors now proactively encourage their partners to use the Misconduct Disclosure Scheme, that facilitates sharing of misconduct data between employers, as part of due diligence funding checks (#3, #10).

3. Coherence, accountability and resourcing

Fragmentation and piece-meal approaches across the international aid system, undermine significant areas of good practice and leadership (eg UN Special Measures, international standards, DAC Recommendation, Summit Commitments), leaving accountability gaps (eg survivor prevention and response, perpetrator impunity, independent investigations, investigatory oversight). Resourcing gaps (financial and technical) compound this challenge. With increasing demands on time and attention, continued progress on safeguarding will require significant political leadership, support and commitment across the system.

4. Human rights and gender equality

The driving forces that enable SEAH (power imbalances, discrimination, marginalisation and harmful social norms that shape organisational and societal culture) are tough challenges that require continued work at international, national and local levels. Human rights and gender equality (#9) need to remain a significant non-negotiable in all international coordination efforts.  This not a given in the current global context of rollback on women’s rights and significant global levels of gender-based violence.

5. Victim/survivor-centred approach

Significant challenges remain in addressing support and accountability to survivors. Whilst the recent IASC Definition & Principles of a Victim/Survivor Centred Approach and the Office of the Victims’ Rights Advocate Statement on Victims’ Rights (PDF, 1.5 MB) provide welcome direction, the practicalities remain difficult, from engaging with survivors and beneficiaries in the design and implementation of initiatives (#1), to ensuring access to services, including access to justice (#5) to having systems fit for purpose (#18), including removing barriers to accessing complaints mechanisms.  A CHS Alliance Foundation Paper (PDF, 15.1 MB), supported by the Netherlands, maps the victim/survivor journey from violation to redress, exploring what an appropriate and effective victim/survivor-centred approach could look like in practice, at each stage. This is a priority area for tackling SEAH.

Next steps

1. Donors will continue to collaborate in various fora to exchange and test ideas, address challenges and pursue joint initiatives to drive up standards and accountability across all areas of summit commitments, including through the examples given above. Focusing on how to support a more unified and coherent international architecture, that is appropriately and sustainably resourced, will be a focus for many. Other areas include: engaging with and taking action following the MOPAN reviews to help multilaterals strengthen their PSEAH work (#13); and continuing to work with the UN to support delivery of the Special Measures (#12).

2. Building on G7 commitments in 2018, 2021 (PDF, 583 KB) and 2023 (PDF, 503 KB) donors will continue to explore options for maintaining political support for tackling SEAH, including through bilateral cooperation (eg Australia-United Kingdom Strategic Dialogue on Gender Equality and the proposed Common Approach to PSEAH).

3. Each donor will continue to take action through our own systems (#21), prioritising measures appropriate to our agencies.

The United Nations

The United Nations (UN) system has taken robust measures over the last 5 years to prevent and respond to sexual exploitation and abuse (SEA) by any of its personnel by working closely with Member States and civil society and building on a suite of measures introduced by the UN Secretary General (UNSG) in 2017.

Progress

1. Leadership

The Voluntary Compact with Member States (105 signatories), and Circle of Leadership on preventing and addressing SEA in UN operations (66 sitting heads of State/governments as members) remains in place. The UNSG continues to publish an annual report updating on progress with implementing his 2017 Strategy for the prevention of and response to sexual exploitation and abuse by United Nations staff, related personnel and implementing partners, and a factsheet (PDF, 332 KB) on initiatives is updated regularly. The Office of the Special Coordinator on improving the UN response to SEA has been in place since 2016; the position of Under-Secretary General became a full time post in 2022. The Office of the Victims’ Rights Advocate (OVRA) mandate and function were created in 2017. The Special Coordinator and the Victims’ Rights Advocate have travelled extensively in the past year to priority countries, notably those with outstanding paternity and child maintenance claims, and engaged in a wide range of internal and external stakeholder engagement activities.

2. Embedding prevention of SEA and sexual harassment (PSEAH) across UN operations

Heads of UN entities at headquarters and in the field are now required to submit annual action plans identifying risks of SEA and mitigation measures. 193 action plans for 2023 were received, and indicate that all entities have a victim-centred policy on the prohibition of SEA, along with related workplans, complaint and reporting mechanisms, and mandatory training for all personnel on the prevention of SEA. System-wide policies and frameworks have also been developed to prevent sexual harassment. The Chief Executives Board (CEB) Task Force on Addressing Sexual Harassment works across UN System entities and has developed a uniform system-wide model policy on sexual harassment to align the policies of UN organisations, as well as a harmonised mechanism for system-wide collection and analysis of data; a common guide for managers to prevent and respond to sexual harassment.

3. Support for victims/survivors of SEA and the Statement of Victims’ Rights

The OVRA seeks to put the rights and dignity of victims of SEA by UN and related personnel at the forefront of prevention and response efforts. The VRA continues to champion and prioritise the rights and dignity of victims by full-time Senior Victims’ Rights Officers (SVROs) deployed in the Central African Republic, the Democratic Republic of the Congo, Haiti, and South Sudan. In 2019, the UN published a Protocol on the Provision of Assistance to Victims of SEA. In 2022, OVRA produced, in collaboration with the International Organization for Migration (IOM), the Office of the High Commissioner for Human Rights and the CEB Task Force on Addressing Sexual Harassment, a UN system-wide training module to provide participants with a clear and practical understanding of what the victim-centred approach means, and what needs to be done to put a victim/survivor first. While intended for UN staff and implementing partners, the training is available to all. In 2022 OVRA launched the ‘victimsrightsfirst’ webpage, which includes information on the training module, victim-centred United Nations policies, and the VRA’s mandate and work. In 2023, the Secretary-General’s High-level Steering Group on preventing sexual exploitation and abuse (HLSG) endorsed a Victims’ Rights Statement (PDF, 1.5 MB) which aims to enable victims of SEA by UN and related personnel to know and understand their rights so that they are empowered to claim them. It serves as a common point of reference for anyone working for the UN, and underscores the Organization’s commitment to put victims’ rights and dignity first. In addition to English, the Statement is already available in, Haitian Creole, Khmer, Polish, Swahili and Ukrainian. OVRA is rolling out translations into UN official and local languages with assistance from a grant from the FCDO, and intends to prepare child-friendly and accessible versions.

4. The Trust Fund in support of victims of sexual exploitation and abuse

The Trust Fund in Support of Victims of Sexual Exploitation and Abuse by UN Personnel administered by the Department of Management Strategy, Policy and Compliance, remains engaged with entities across the United Nations system to assist victims of sexual exploitation and abuse. In 2021 to 2022, the Trust Fund supported the implementation of 8 projects, including a first project in South Sudan. Outreach has been conducted to solicit proposals to cover service gaps in locations where there are UN-related victims of SEA. A funding appeal was also sent to Member States so that the Trust Fund can raise $4 million in the next 2 years to be able to support critical projects and gaps in services. The Organization remains grateful to the 24 Member States who have contributed to the Trust Fund.

5. Improving PSEA in the humanitarian sector

In 2018, the  Inter-Agency Standing Committee (IASC) endorsed a Plan for Accelerating PSEA at Country Level which commits members to scale-up PSEA activities through collective investment in humanitarian response at the country level. In 2020, the UN High Commission for Refugees (UNHCR) in collaboration with the World Food Programme (WFP), the IOM and other IASC members, adapted an interactive training programme for frontline humanitarian workers, “Saying no to sexual misconduct.” It is open source and has been adapted for use in various field locations and languages. In 2021, UNFPA commissioned an independent external review of PSEA (PDF, 4.8 MB) in the humanitarian sector from 2011 to 2021 which found that the IASC had promoted standards and initiatives to address strategic priorities, such as coordination capacity at country level, inter-agency complaint mechanisms, and reference-checking. The review also found that the scale, predictability, and consistency of resourcing remain constrained, and more is required to build an understanding of the content of a victim/survivor-centred approach, and the requirements for its implementation. At the global and country levels, accountability for prevention was enhanced and the roles of actors on the ground were clarified. The findings of the review led to the endorsement of a 5-year IASC Vision and Strategy on PSEA 2022 to 2026 with commitments to embed sustainable and accountable PSEA actions within all humanitarian contexts, and to transform culture change across the sector.

6. Employment screening and vetting

The ClearCheck system was launched in 2018 to ensure that UN personnel with substantiated allegations of SEA and sexual harassment are not rehired in another part of the system. It includes records of those who left the organisation with a pending investigation or disciplinary case related to SEA. 35 UN entities are participating in the system. UNHCR is also piloting participation in the Misconduct Disclosure Scheme and the Secretary-General has encouraged discussion of how these parallel screening systems could operate together.

Challenges and lessons

1. Need for dedicated services for victims/survivors

In many locations where UN agencies operate there are gaps in services available for victims/survivors of SEA. In 2021, the OVRA administered a survey in 13 countries to update information on progress in realising the rights of victims to services. The results showed some improvement but also persisting gaps. Among these are that services are predominantly provided through existing gender-based violence programming which is underfunded, and providers may not be familiar with SEA, and the singular needs of victims, such as legal support for paternity/child maintenance.

2. Resource constraints

Dedicated inter-agency PSEA Coordinators have a critical role in driving implementation of a PSEA action plan through leading a network of PSEA focal points from the country teams. Continuous PSEA commitment is hampered by high turnover of personnel and a lack of predictable and sustainable funding, causing gaps in the implementation of agreed-upon collective PSEA activities. Securing sustainable resources for PSEACap, the IASC project to deploy PSEA Coordinators in 15 high-risk SEA countries, remains a challenge. In addition, resources are needed for activities prioritised in country PSEA action plans. As a result, it becomes imperative to continue advocating for funding for both the PSEACap project and country PSEA action plans, as these are crucial for collectively tackling the issue of SEA in these high-risk contexts.

3. Ensuring accountability of perpetrators and justice for victims and survivors remains a challenge

The UN continues to refer credible allegations of SEA against UN officials and experts on mission to their States of nationality. This however seldom leads to arrests and indictments, although not all SEA offences are criminal in nature. Some minor progress in resolving paternity and child support claims has been made. However, pursuing alleged fathers across jurisdictions is time-consuming, as victims lack access to legal assistance and legal processes to realise these claims are complex. It is particularly challenging where the alleged father cannot be located, has no means of paying maintenance, or has died.   

4. Ongoing allegations of SEA linked to peacekeeping troops

In response to credible reports of widespread SEA, combined with a history of non-responsiveness by national authorities to allegations from earlier years, the UN Secretary-General repatriated a contingent from the United Nations Multidimensional Integrated Stabilization Mission in the Central African Republic (MINUSCA). The Secretariat established a multidisciplinary team to examine, in close collaboration with MINUSCA and other field missions, the factors that contributed to a higher number of allegations in 2021. High-level engagement with Member States on prevention and accountability for pending allegations of misconduct is ongoing. Work continues on the Pipeline to Peacekeeping Command Programme, aimed at strengthening the leadership capacity of senior and middle-level commanders to foster effective conduct and discipline in a peacekeeping operation.

Case study from IASC: Leadership and engagement through IASC champions on PSEA and sexual harassment

Visible leadership has led to some progress across the system. Since 2011, the IASC has designated Champions for PSEA who commit to providing visible leadership and overseeing results. As executive heads of their agencies, they can bring additional resources and leverage support. IOM contributed by designing and professionalising the role of the inter-agency PSEA Coordinator at country level, with endorsed Terms of Reference, skills training and a deployment package. In 2018, UNICEF brought its own resources to fund several Coordinator positions, and further developed an acceleration plan at country-level and initiated mapping to track progress, represented through an IASC website on PSEA. UNHCR focused their championship on the promotion of the respectful use of authority, including funding the development of an inter-agency training package for partners and convening a session on values, culture and attitudes with IASC leaders and Humanitarian Coordinators. UNFPA continued providing Coordinator capacity, bolstered case management of SEA, and access to assistance for victims by strengthening referral pathways to gender-based violence services, and commissioned the independent External Review World Vision International, as Chair of the Steering Committee for Humanitarian Response, led the development of the IASC victim-centred approach and developed the PSEACap project to provide dedicated and predictable PSEA coordination capacity to the highest risk emergencies. They have actively engaged with humanitarian leadership to promote zero tolerance for inaction.

Next steps

Much has been accomplished since 2018 but much more remains to be done, particularly in ensuring effective delivery at the country level, in working coherently and consistently across the UN system and with our partners, and in strengthening our interventions to further improve transparency, accountability and support to victims. The UN remains committed to eliminating sexual misconduct from within the aid and peacekeeping sectors. This requires greater recognition that this is a core responsibility of each organisation and an integral part of the “cost of doing business”. Priorities for the future are:

• IASC to deploy dedicated PSEA Coordination capacity to SEA high risk contexts to support humanitarian leadership through the PSEA Capacity project
• enhanced communication and engagement with communities where humanitarian assistance is delivered, and country level protocols to ensure all complaints are appropriately followed up
• improved investigations to ensure more timely resolution, better communication with victims, and full implementation of the victim/survivor centred approach. The OVRA will continue to devote significant resources to advocacy for the resolution of outstanding paternity/child maintenance claims, and as part of that intends to focus on providing early legal assistance to victims and their children
• enhanced communication within the UN system to ensure a clear understanding of the prohibition against Sexual Exploitation and Abuse (SEA) and the consequences for violators, to foster a culture change, to promote accountability, and to cultivate an environment free from sexual exploitation and abuse across the organisation
• improved coordination with civil society organisations, external partners including international, regional, sub-regional organisations, Member States, the private sector, and academic institutions to leverage their expertise in addressing SEA issues
• institutionalisation and integration of Protection from Sexual Exploitation and Abuse (PSEA) into United Nations activities and programs, and establishment of sustainable and predictable funding for PSEA efforts globally
• The Office of the Victims’ Rights Advocate will prioritize further engagement with the United Nations internal justice system to sensitise judges on victims’ rights and seek to introduce a victims’ rights approach in internal investigations of sexual exploitation and abuse and sexual harassment
• following the launch of the training module on the victims-centred approach to sexual exploitation and abuse and sexual harassment earlier in 2023 (see above), the Office of the Victims’ Rights Advocate is developing the network of trainers-of-trainers to deliver the module globally. Introducing the module in various settings and sensitising as many staff as possible on the victim-centred approach will be a strong focus going forward

International financial institutions (IFIs)

Ten international financial institutions (IFIs)^{[footnote 5]} reaffirmed their commitment to advancing standards to prevent sexual exploitation, abuse, and harassment (SEAH)^{[footnote 6]} on 18 October 2018. They committed to create an environment where SEAH is not tolerated in accordance with the 7 common principles^{[footnote 7]} agreed upon by the IFIs. This report provides a brief overview of the main advancements, challenges, and lessons learned by 6 (ADB, AIIB, EBRD, EIB, IDB, and the World Bank, including IBRD/IDA and IFC) of the ten IFIs over the past 5 years (2018 to 2023). While recognising that IFIs differ in their policies and procedures, nearly all IFIs have adopted many of the common SEAH principles, both institutionally and operationally.

Progress: Institutional measures

1. Capacity building and training for staff

Most IFIs developed and delivered new training programs to raise awareness and build capacity for identifying, mitigating and responding to SEAH risks, such as building a ‘speak- up’ culture in the workplace; combating gender-based violence (GBV), domestic violence, and all forms of harassment including psychological harassment (with some emphasis on LGBTQI+); enhancing women’s security in the workplace; and providing mandatory ‘Ethics’ and Code of Conduct online courses (regular and refreshers) that address SEAH issues. Some ethics training highlighted emerging risks such as the ability to create sexualised images of co-workers via artificial intelligence (AI). One IFI rolled out a mandatory training course on respectful workplace and organised a retreat for senior management that highlighted “Senior Leadership as Role Models and Respectful Work Environment”. Additionally, IFIs have offered training on procurement and contractor accountability for SEAH, and developed guidance materials for contractors in identifying and reporting workplace concerns.

2. Reporting through applications and other ICT-based methods

IFIs have innovated in providing anonymised ways of reporting SEAH. One such example is a secure web and mobile application for anonymous reporting by both internal and external persons. Another IFI has developed an automated and autonomous tool for confidential and anonymous reporting, and addressing incidents of harassment, abuse of power, and discrimination. This tool has an interactive platform, which uses AI to interact with employees on their concerns and is supported by training to build employees’ capacity to report SEAH. One IFI has launched an AI chatbot, designed to be accessible and informative to anyone within the institution, especially those who might feel uncomfortable reaching out initially.

3. Internal policies, SEAH working groups, and new staff positions

In line with the growing emphasis on addressing SEAH within organisations, IFIs have undertaken reviews of their codes of conduct and whistleblower policies to create a more enabling environment and organisational culture to effectively address SEAH issues. Promoting psychological safety and ensuring that staff can speak up remains a priority for IFIs. In collaboration with external partners, many IFIs have expanded their approaches to preventing and addressing sexual harassment at work. Another IFI introduced the ‘Equilo’ data-based platform that provides decision-makers with comprehensive data on GBV. IFIs have deepened their collaboration through the establishment and regular meetings of an IFI SEAH Working Group. Respective approaches to SEAH are shared through this platform, including risk screening and grievance management, staff capacity building, and common framework. A joint multilateral development bank (MDB) website portal for sharing SEAH-related resources has been launched to strengthen MDB collective approaches in this area. Some IFIs have created new and dedicated staff positions to strengthen their commitment and capacity to address SEAH, such as IFI staff positions, anti-harassment coordinators, investigators, and SEAH and GBV specialists.

Progress: Operational measures

1. Enhancement of safeguard policies and procedures

IFIs have strengthened or are in the process of strengthening their environmental and social policies and related standards to better address operational SEAH risks. Some IFIs have updated their Environment and Social (E&S) Frameworks, including strengthening provisions to address, avoid, or mitigate GBV and SEAH risks. Some IFIs have also organised training on SEAH risk management, including survivor-centred grievance mechanisms, incident response, and complaints mechanisms. Additionally, some IFIs have revised their standard procurement documents to include code of conduct templates, which contain relevant provisions on GBV/SEAH management for consultants, contractors, and employees, or developed due diligence procedures and reporting protocols to operationalise new requirements related to gender-based violence and harassment (GBVH). One IFI also developed a disqualification mechanism for non-compliant contractors.

2. Development of new guidance materials, SEAH risk assessments and monitoring tools

Over the past 5 years, IFIs have invested in updating or developing new SEAH-related guidance and resource materials. 2 IFIs, for instance, prepared step-by-step guidance for E&S specialists and other staff engaged in operations to assess SEAH risks during project preparation and incorporate preventive measures in the project cycle. Several IFIs have developed ‘good practice notes’ on preventing, mitigating, and responding to SEAH in civil works (PDF, 1.3 MB) and other relevant sector operations (PDF, 1.2 MB) while other IFIs developed guidance tools and resources for their private sector clients to mitigate and manage the risks of GBVH in their own companies. One IFI is also addressing SEAH using a community-based grievance mechanism toolkit, which includes guidance for accountability to affected populations. Several IFIs have developed and/or rolled out new risk assessment tools to strengthen the identification of risks associated with GBV, including SH and SEA, so that appropriate mitigation measures can be applied. For example, one IFI launched a company GBV self-assessment tool to help private sector companies assess their capacity and frameworks across 9 key domains including leadership, culture, human resources, community and stakeholder engagement, and roadmaps to address GBV and SEAH. One IFI created a task team which provides technical assistance to borrowers/clients on serious incident escalation, survivor-centred incident response, connecting survivors to care, and implementing code of conduct and ethical accountability frameworks. Communities and individuals affected by projects financed by this IFI may complain to its compliance advisor ombudsman office. One IFI created a task team which provides technical assistance to borrowers/clients on serious incident escalation, survivor-centred incident response, connecting survivors to care, and implementing code of conduct and ethical accountability frameworks. Communities and individuals affected by projects financed by this IFI may complain to its compliance advisor ombudsman office.

Case studies

Case study 1

This case study involves the financing of approximately 230 kilometres of road in a critical regional transport corridor that connects 2 Sub-Saharan African countries with better safety and climate resilience. Conflict sensitivity analysis was conducted given the security issues in the region. Furthermore, substantial technical assistance will be provided to build both climate and social capacity for the project. GBV/SEAH was identified as one of the project’s main risks during due diligence. The client agreed to hire a specialised consultant for 3 years on a part-time basis to address these GBVH risks. In addition, the client will work with a local NGO to collect and address GBV/SEAH-related complaints at the community level. To minimise adverse impacts on women and enhance positive ones (especially employment-related), all E&S management plans will be required to apply and adhere to a gender lens.

Case study 2

An IFI’s office of ethics received an allegation of sexual harassment and disrespect in the workplace regarding inappropriate comments made by a high-level employee. Following a preliminary investigation, and with the victim-survivor’s consent, the case was referred to the human resources (HR) department. The HR department head, ethics officer, and employee’s supervisor issued verbal warnings to the employee. Moreover, the warning outlined the IFI’s anti-retaliation policy and emphasised the requirement under the code of ethics that supervisors demonstrate the highest ethical standards.

Case study 3

One IFI is investigating a case alleging SEA which is in its preliminary inquiry stage. Twelve staff were cautioned for inappropriate sexual behaviour, and management dealt with 6 additional situations involving external parties. In the legal agreement between the IFI and the borrower, the IFI took a comprehensive and phased approach to SEAH. Mitigation measures were linked to project disbursement indicators, and technical assistance was provided to existing in-country GBV actors. The grievance mechanism included a provisional national hotline with the capacity to refer SEAH survivors to emergency support services, as well as basic services and referrals in target provinces.

Challenges and lessons

1. Promoting a ‘speak- up’ culture is crucial at the institutional and operational level

In spite of an increase in reported SEAH cases within IFIs and operations, cases remain significantly underreported. Growing and nurturing the ‘speak-up’ culture within IFIs has been a major challenge. Various approaches have been taken by IFIs to deal with this concern. In addition to e-learning and capacity building, IFIs offer modules focused on sexual harassment in the workplace to foster a speak-up culture and strengthen existing reporting and support mechanisms for whistleblowers. Also, IFIs encourage managers to provide support to their teams so they can speak up.

2. Limited awareness and understanding of how to apply survivor-centred approaches

There is still a lack of awareness and capacity among IFI staff and clients when it comes to addressing GBVH/SEA/SH risks that arise in the workplace or stem from operations. As a result, clients and staff find it difficult to comply with IFI requirements related to addressing and preventing these risks and implementing action plans. Moreover, the absence or low capacity of GBV services, such as health, psychosocial, protection, legal, and livelihood, hampers survivor-centred responses to SEA/SH incidents. Despite their admirable efforts, IFIs often offer short-term and specific training. In agencies where staff turnover is high, more intensive and sustained training programs is needed.

3. Effective monitoring, evaluation, and reporting of operational SEAH cases

Although additional emphasis has been placed by IFIs on reporting incidents and allegations, some clients are still not reporting regularly. To address this, IFIs are improving their monitoring, conveying no tolerance for SEAH to clients, and ensuring that clients are accountable. Tools and systems must be developed and implemented to close knowledge gaps and improve methods to foster the effectiveness of SEAH risk management and active reporting in operations. Alternative financing and analytical work by IFIs can be used to mitigate SEAH risks and strengthen country systems. There is growing demand, including from the private sector, to have SEAH risk management guidance and training tailored to specific sectors and modalities. One IFI’s efforts are underway to respond to this demand.

Next steps

Over the coming years, all IFIs will continue to implement and strengthen SEAH policies, guidance, and action plans, focusing on capacity building and client training for public and private sectors. IFIs will provide more guidance and mandatory training programs, strengthen reporting systems, and develop psychological safety initiatives and a talent pool of trained consultants to assist projects in addressing SEA/H risks. Some IFIs are also considering creating dedicated SEAH-specific technical staff positions. All IFIs will continue their efforts to better coordinate, harmonise, and align their approaches to SEAH across their respective operations.

UK non-governmental organisations (represented by Bond)

On 18 October 2018, UK international development non-government organisations (INGOs) presented a set of commitments to tackle sexual exploitation, abuse, and harassment (SEAH) (PDF, 271 KB) These were developed by Bond, in consultation with its +350 members, and set out the INGO sector’s approach to improving the quality and consistency of their safeguarding policies and practices. The safeguarding commitments form part of the Bond charter which all Bond members sign up to.  

Progress

For the last 5 years, Bond has been driving up safeguarding standards across our membership and has supported organisations to develop robust safeguarding policies and practices. Over this period, we have:  

• developed tools and resources to help our members and others in the sector improve their practices on reporting and complaints mechanisms, as well support with regards to  safeguarding governance for trustees We have also developed case studies to demonstrate how NGOs are using our sector commitments. Most recently, we  published 3 case studies to support organisations and their partners who currently use FCDO’s Preventing SEAH Due Diligence Guidance
• supported organisations to adopt a safeguarding culture and improve their safeguarding leadership through our leadership and culture tools
• built capacity and capability of members and across the sector through our safeguarding training and our regular engagement activities with members. Most recently, we heard from small organisations through a listening exercise to help better understand the challenges that they are facing with safeguarding – we have been using this feedback   to design and deliver learning sessions which have taken place throughout 2023 and will continue into early 2024
• supported other professionals in the sector by amplifying the voice of our members in other spaces. We have had the opportunity to do this with the Resource and Support Hub, where we shared our thoughts on their plans and we provided  the ‘NGO Safeguarding Network (Global)’ a sense of the progress and challenges around  safeguarding across the UK sector from a Bond member perspective. In addition, Bond continues to share resources and hosts regular learning opportunities

Each year, Bond asks its members to reflect on the progress they have made towards better safeguarding practices within their organisations and the wider NGO sector. This information has been compiled in the ‘Bond 2023 Safeguarding Survey’, which was completed in August 2023 by 40 Bond member organisations, and also includes previous member surveys for comparison.  We have seen significant progress in different areas of safeguarding over the last 5 years:  

1. Better safeguarding practices

All respondents of Bond’s 2023 safeguarding survey shared that they have seen progress towards better safeguarding practice in their organisation over the last 5 years since the Global Summit of 2018. 75% of reporting organisations shared that in the last 5 years, they have made improvements to safeguarding practice that is benefitting communities.  

Organisations that have engaged with Bond on safeguarding have reported progress in different areas of safeguarding such as: enhancing their training packages; strengthening their safeguarding policies sharing resources with partner organisations to improve practice across the sector and embedding safeguarding cultures in their organisations; and working harder to hold leaders to account. 

In addition to Bond resources, organisations stated that joining the Misconduct Disclosure Scheme has enhanced their safeguarding practices.  

2. Increased resourcing

Year on year since 2018, Bond members have reported increased resourcing for safeguarding:

• 74% of organisations suggested that they had increased safeguarding resourcing in 2019
• 64% in 2020
• 62% in 2021
• 51% in 2022
• 52.5% in 2023

Although less and less organisations are suggesting that they are increasing each year, over half of responding Bond members have still increased their resources year on year.   

Increased safeguarding resourcing suggests that safeguarding is no longer a taboo subject within organisations. More resources suggest there is more awareness, and engagement on safeguarding has increased – which has supported organisations to move away from focussing on safeguarding compliance to having an embedded safeguarding culture. 32.5% of respondents also shared that they had increased their safeguarding training offer within their organisations. 

Positively, some NGOs have reported that their safeguarding work is a priority and although they are suffering financial difficulties in their organisations, they have re-evaluated budgets to ensure that their safeguarding budgets have not been affected.   

3. Survivor-centred approach

Support for victims and survivors has increased in comparison to 2018: 75% of responding organisations in 2023 have increased support for survivors. For example, organisations have adapted survivor-centred approaches throughout their programmes focussing on how to deal with concerns that have been raised. In addition, they have focussed on how they communicate with communities. Organisations have reported that there has been an increased trust in safeguarding processes in local contexts because of the support that has been offered to survivors.  

4. Organisational knowledge and confidence in safeguarding

All respondents have suggested that their knowledge and confidence on good safeguarding practice has increased over the last 5 years, with the majority of respondents reporting a significant increase. To ensure that the wider sector benefits, Bond members are able to share their increased knowledge through webinars, blogs and case studies.  

5. Safeguarding culture

Organisations have been working to create and build on their own internal safeguarding culture, starting with increased oversight at leadership level.

Leaders in organisations have been working on their safeguarding culture by using Bond’s culture tools – in the last 12 months alone there have been 42 downloads of the ‘Developing and modelling a positive safeguarding culture: A tool for leaders’ worldwide, 35 of those downloads were in the UK. Feedback from organisations suggests that an embedded safeguarding culture has not only had a positive impact on better safeguarding practices within their own organisation, but it has also supported their organisation’s approach to planning and resourcing safeguarding in their programmes, for example, the budget and investment needed in staff and resources. Leaders in organisations with an embedded safeguarding culture understand their systems to preventing sexual exploitation, abuse and harassment which filters down to survivors in local contexts. Without taking a cultural approach to safeguarding and promoting a safe culture in organisations, none of the above progress would have been possible.  

Challenges and lessons

1. UK aid cuts and financial pressures  

A quarter of all organisations reported to Bond that their safeguarding progress has continued to be impacted by the UK aid cuts and other financial pressures. Organisations have said that due to financial pressures they have had to make difficult decisions about budgets, which means they can no longer afford training, to support their local partners, or increase staff time spent on safeguarding.   Bond has continually heard that many small organisations are facing particular challenges related to financial pressures. For example, organisations are unable to afford to translate safeguarding training packages or resources to support their colleagues in lower- and middle-income countries or provide emotional wellbeing support for safeguarding practitioners. Organisations also do not have the staff time to be able to seek out additional resources that are available from elsewhere to help strengthen their practice.   

2. Time dedicated to safeguarding  

Half of the NGO respondents to our survey still do not have a full-time safeguarding post, which means safeguarding responsibilities are often added to an existing staff post. Where safeguarding forms part of another role, competing priorities might mean less time is dedicated to safeguarding.   Safeguarding Leads at NGOs (of which 73% of survey respondents were) have reported that they are under more pressure from competing priorities and therefore unable to apply the same amount of resource to safeguarding as they would like. Bond has heard there is an increase in wellbeing concerns across safeguarding professionals as a result of not having the budget for more staff time. Safeguarding professionals are also seeing a lack of peer support. Time pressures mean there is less time to engage with the sector and sector learning, leading to a lack of peer support and sharing of good practice.   

3. Safeguarding in partnerships   

NGOs that work with local partners are continually working on how to support partner organisations. However, 65% of respondents reported they would like further help with this on-going challenge.  Areas that organisations find particularly challenging are:  

• trying to develop initiatives to support safeguarding practices in local contexts whilst maintaining principles of shift the power (adopting effective locally led approaches)
• sourcing affordable training, in the right language and pitched at the right level
• flipping compliance conversations on their head and starting conversations with partners on how they protect communities, then translating this into commonly used safeguarding terms to develop best practice

4. Local context support needs

57.5% of respondents suggested they still need further in-country specific advice on context or support services. The added complications around working in a variety of contexts means that different settings require widely different safeguarding processes – these include: (but are not limited to) risk assessments, reporting mechanisms and safer recruitment methods.  

UK organisations working with local partners frequently need support from their partners to understand the local context, regulations, and laws. Organisations that provide short, accessible resources that are translated and are available in local contexts are beneficial to working locally.  

The sustainability of initiatives, such as the Resource and Support (RSH) National Hubs in Ethiopia, Nigeria, South Sudan, MENA, South Asia and Eastern Europe are crucial for the sector, to avoid losing valuable resources and having to reinvent the wheel.   

5. Sustaining momentum   

Bond is seeing a decrease in organisational engagement in relation to safeguarding across our membership. While we continue to engage with members on safeguarding, this decrease is particularly evident when we look at the number of survey responses that we have received over the last 5 years.   

Survey responses peaked and are now beginning to trough since the 2018 Safeguarding Summit. Response rates since 2018 are: 

• 2018: 62 respondents (pre-global summit)
• 2019: 97 respondents
• 2020: 129 respondents
• 2021: 144 respondents
• 2022: 51 respondents
• 2023: 40 respondents

While we continue to see high levels of engagement from safeguarding practitioners, we believe that the focus of leaders in organisations has somewhat shifted to other areas, such as anti-racism, decolonisation, being locally led, as well as ensuring financial sustainability and operating in a difficult external environment. This means that the conversation around safeguarding at leadership level needs to be revitalised. 

Case study: Concern for Children and Women Empowerment (COFCAWE)

All We Can (a Bond member) advocates for locally-led working, in local communities, expressed through the partnership model they follow with their international partners. This year, they supported their local partner in Uganda, Concern for Children and Women Empowerment (COFCAWE), to pilot a community-level safeguarding project, enabling COFCAWE to increase their community safeguarding committees (SGCs), each comprising 5 community members who are responsible for supporting abuse survivors and reporting to authorities, from 5 to 11, located in 35 villages.

The pilot achieved its long-term objectives by establishing community by-laws to strengthen community-level child protection, providing psychosocial and medical support to survivors and equipping communities and SGC members with knowledge on child protection laws and abuse case reporting processes. The pilot has equipped 50,000 parents and 100,000 children with knowledge on child protection and reporting processes. As a result, 79 abuse cases have been reported to the SGCs, with 15 cases reaching the police, and 4 currently at court level. 10 survivors have received essential social and medical support.

COFCAWE, 2023:

We are pioneering a safeguarding model that puts communities at the centre of their safeguarding and protection of children and vulnerable people. COFCAWE can move away from a village and these committees will persist in protecting communities.

Next steps

1. Supporting organisations to understand the importance of safeguarding professionals’ wellbeing  

During our small organisations listening exercises, we are starting to see a trend around the minimal support organisations are offering their safeguarding professionals. This puts them at risk of emotional wellbeing difficulties due to the traumatic nature of the work they are undertaking. Bond is starting to support organisations with this through an upcoming skills mapping session in early 2024 and will continue to work alongside members to provide accessible advice in this area.   

2. Sharing learning  

In the next 12 months, Bond and its members will continue to support each another through peer learning of what has worked as good practice in their organisations on the following thematic areas Bond has prioritised in 2023:  

• developing learning that works - tailoring training that is the right fit for your organisation
• safeguarding practitioners’ emotional wellbeing
• converting what organisations are already doing on safeguarding into written compliance
• embedding safeguarding culture within an organisation
• being incident ready

Bond also plans to share learning by continuing to support NGOs with their relationship with the Charity Commission England & Wales.   

3. Promoting Bond’s case studies on applying FCDO’s SEAH due diligence and continuing to support safeguarding in partnerships

Bond and its Partnerships and Local Leaderships working group have developed a suite of 3 case studies to share examples of how the FCDO due diligence guidance has been applied in other organisations. Giving implementing partners an idea of how they can successfully achieve a positive due diligence assessment and will provide downstream partners a practical understanding of the assessment.  

Organisations are continuing to struggle with safeguarding in partnerships. Bond has identified that we need to change how we are supporting partners and make our support offers more accessible. 

UK private sector suppliers (represented by the Safeguarding Leads Network)

The Safeguarding Leads Network (SLN) was established as a ‘second tier’, membership network in May 2019. There are now 34 members, (37 before the merger of some member organisations mergers). Any private sector implementer of UK ODA programmes can join the SLN on the condition that they sign up to the private sector commitments to prevent and respond to sexual exploitation, abuse, and harassment (SEAH), presented in October 2018.

Over the last 5 years, while the SLN notes that significant gains have been made in progressing sector-wide best practice, progress has been uneven between SLN member organisations and anecdotally members have raised concerns around maintaining momentum for change, in the context of external constraints and competing priorities. The SLN is committed to supporting members to drive up standards and acts as a forum to share learnings, monitor progress and build technical capacity. This year, the annual survey on progress was completed by 56% of SLN members to a variable extent. The answers presented below represent responses where safeguarding leads had access to the relevant information.

Progress

Progress area 1: Developing and strengthening relevant policies

The majority of respondents noted this as the most significant area of progress since 2018. In some cases, initial stand-alone or safeguarding-relevant policies have been reviewed annually, with a focus on deepening and contextualising policies and processes and with attention to cultural sensitivity. An example of the maturation of policies is that, in some cases, organisations have shifted their focus to developing appropriate monitoring and oversight structures to ensure that policies and procedures are implemented effectively.

Progress area 2: Designing and implementing ‘speak up’ mechanisms (staff)

SLN members report that clear and contextualised ‘speak up’ mechanisms continue to be an area of focus. The visibility of mechanisms, through focal points, differing business functions, and at Board level were also key areas of activity. Some members have also developed multiple pathways to reporting, reflecting a recognition that receiving reports is a positive indication that reporting mechanisms are both essential and effective.

Progress area 3: Organisational culture

This has been a key area of focus for a number of SLN members over the past 5 years. Visible buy-in from senior leadership and regular communication campaigns are mechanisms that some members report as effective methods to embed a safeguarding culture. Other interlinking elements, such as training and strengthening in-house, safeguarding capacity (see below), were also referenced as key pathways.

Progress area 4: Strengthening in-house capacity on safeguarding

Members are increasingly reporting that they have recruited safeguarding specialists to lead their organisational commitment to safeguarding, and in a few cases, building safeguarding teams or safeguarding committees with membership across business functions to ensure that safeguarding best practice was integrated in all aspects of delivery. Hiring specialists is reported by members as a means to make progress on issues such as investigations.  At the field / project/programming level, members report that identifying safeguarding focal points is useful for embedding safeguarding policy and practice.

Progress area 5: Training of staff and contractors

Training of staff and contractors remains a key area of focus for some SLN members. Organisations have increasingly reflected the need for contextualisation of training, and some members have indicated that they have developed additional resources for teams to assess the safeguarding capacity of partners and their supply chain. Training has been identified as one of the key drivers of cultural change.

Progress against last year’s challenges

2022 Challenge 1: Designing and implementing ‘speak up’ mechanisms (for communities, beneficiaries, and others)

Examples of new initiatives undertaken by members include a safeguarding-specific email address; organisational or external hotlines/speak up lines and phone numbers (especially where toll-free); community-based mechanisms; safeguarding focal points; improved information on organisations’ websites and including reporting in staff and partners’ training. The focus in these cases has been to create accessible, relevant, and contextual reporting processes and information sharing, taking into consideration language, translation, and partners’ operating modalities. Some members have reviewed their Standard Operating Procedures (SOPs) on reporting or developed guidance on speak-up mechanisms. Some members report that Training of Trainers programmes, staff on-boarding sessions and communications campaigns have been designed to build the confidence of staff in reporting mechanisms.

2022 Challenge 2: Survivor-centred response to reported concerns

In some cases, the organisational and individual understanding and application of the ‘survivor-centred approach’ has been done a number of initiatives including the following: in-house trainings involving scenario  and simulation-based trainings so that, for instance, those conducting investigations or taking remedial actions understand the difference between ‘survivor-centred’ and ‘survivor-led’ approaches; reviews of SEAH policies  and case management procedures while strengthening reporting and investigation processes; developing a trauma-informed care toolkit; a study on perceptions of safety and SEAH in relation to gender and sexuality; partner-led mapping for referral pathways and 24/7 access to mental health services  and support for survivors. There has been more focus on understanding consent and confidentiality issues.

2022 Challenge 3: Challenges relate to designing and implementing safe programmes, strengthening in house safeguarding capacity, and working with partners

Members’ focus has been on allocating additional human resources for safeguarding including full-time staff, consultants and external experts. Safer recruitment initiatives including the Misconduct Disclosure Scheme (MDS), engaging with the SLN network, developing minimum standards for programming, and implementing the ‘do no harm’ approach are reported as activities in progress. Organisations have created resources and guidance for suppliers, partners and projects. Increased attention to process reviews and risk assessment is reported by members, while capacity building continues through internal and partner level training.

Challenges and lessons

SLN members report developing a variety of strategies and approaches to meet a range of challenges.

Challenge 1: Strengthening in house capacity on safeguarding

The majority of respondents noted that strengthening in house capacity on safeguarding remains a challenge. Although it is a priority and members have been attempting to build capacity through training and their engagement with the SLN, the recruitment of dedicated safeguarding resources varies widely across the membership. This challenge is very much linked with Challenge 5, related to funding.

Challenge 2: Planning and conducting investigations

Although members’ capacity and understanding of planning and conducting investigations is evolving through investigation training (including the Investigator Qualification Training Scheme IQTS) and the development of internal protocols, respondents note that they are often caught between the challenge of building internal investigative capabilities and the high cost of external, independent, safeguarding experts and investigators who may better understand the local context.   

Linked to this challenge is that of reporting (see below). Members report under-reporting as a significant challenge. Almost half the respondents had no reports in the last 12 months and where reports were received they were mostly related to sexual harassment at work with few cases from community members.

Challenge 3: Working with partners

Members highlight the significant investment and intensive activity that is needed to meet donor safeguarding due diligence requirements across the supply chain, given that while members are improving their internal due diligence and risk management processes, not all partners are able to provide the evidence needed or have the capacity to implement safeguarding requirements. These issues can hinder the trust-building that members are striving to achieve, especially with smaller partners.  

Challenge 4: Safer recruitment

Many members are trying to make their recruitment processes safer, by embedding strong due diligence processes and integrating safeguarding into all stages of the recruitment cycle. While implementation of the provisions of the Misconduct Disclosure Scheme (MDS) varies across the membership, members continue to express interest in the MDS, and are holding sessions to overcome some operational challenges.

Challenge 5: Financing safeguarding  

Many of the challenges that members face are underpinned by the constant issue of financing, leading directly to some organisations’ drop in momentum. Members note mixed messaging from clients/donors on the availability of dedicated safeguarding budgets in light of budget cuts, and the increasingly commercially competitive bidding landscape. While safeguarding is not ring-fenced as a non-competitive budget, members report finding it a struggle to convince their business development and commercial teams to build in dedicated safeguarding budgets, especially in small and medium enterprises (SMEs).

Case study: This case is a reflection of the type of issues private sector organisations are dealing with across the sector

A very junior member of project staff informed her senior management that a male staff member was engaged in sexual relationships with other, junior female staff. Senior management immediately informed the safeguarding and ethics team. The organisation launched an investigation into potential sexual harassment and / or sexual exploitation. The head of HR in-country conducted the investigation, mentored by the organisation’s safeguarding lead. The women all denied that they had been exploited or were ‘victims’, but there was credible information that the male staffer had done what was alleged. In line with both the victim/survivor-centred approach and national law, he was given a hearing and resigned.

Why is this case positive? The project’s senior managers had created a culture of safeguarding in the team and knew what to do when they received the report. This would not have happened 2 years ago and certainly not 5 years ago.

The junior staff members are now aware that the organisation takes this seriously and takes appropriate action. The organisation is also using this case (anonymised) in its annual training for all staff to underscore that it takes all concerns seriously, regardless of the status of the alleged victim/survivor or reporter.

Next steps  

There is continuing interest among the SLN members on safer recruitment, particularly on learning more about initiatives like the Misconduct Disclosure Scheme and Project Soteria. Mental health and wellbeing of employees with responsibility for safeguarding is an emerging theme. The need for organisational capacity-building remains and SLN members echo previous years’ recommendations for sharing good practice and cross-sector learning, with focus on investigations, application of the survivor-centred approach and safeguarding in emergencies ). SLN discussions more widely reveal that organisation capacity remains a key priority; which provides an important nuance as the survey represents a 56% response rate.

SLN members also recognised the importance of signposting useful resources and sharing of best practices from across the sector and beyond. The need to address the lack of funding and resources for safeguarding against SEAH was also identified. The need to advocate with donors and funders as a group to encourage budgeting for safeguarding along with mandatory safeguarding activities in projects is a sector priority.

The SLN will continue to support members in building knowledge and raising awareness to ensure continuous improvement and ensure that safeguarding remains a priority. The SLN looks forward to continuing to working with FCDO and across the sector on fulfilling our collective safeguarding commitments.

Research funders (UKCDR)

In 2018, 5 UK funders of international development research^{[footnote 8]} jointly committed to raise safeguarding standards across the sector (PDF, 230 KB), in order to prevent and tackle all incidents of harm and abuse, including sexual exploitation, abuse and sexual harassment (SEAH), building on existing good practice. Funders worked closely with the UK Collaborative on Development Research (UKCDR) to develop guidance on how to raise safeguarding standards – including on SEAH – which was published in April 2020. Since the joint commitment, UK research funders have been working together and within their organisations to develop and implement their safeguarding policies and guidance.

Progress

1. Continued commitment to the implementation of safeguarding policies and principles

UK research funders continue to demonstrate commitment to raising safeguarding standards across the sector since 2018, through efforts such as developing, and publishing relevant safeguarding policies or reviewing existing guidance. The National Institute for Health and Care Research (NIHR) is currently updating several sections of their Safeguarding Policy, which was published in 2020 and revised in 2021. The policy sets out the standard NIHR approach to safeguarding and provides guidance for those involved in managing NIHR programmes. Similarly, UKRI’s Preventing Harm policy (PDF, 8.3 MB) remains in place, and UK Research and Innovation (UKRI) have received feedback from the research community that the policy is appropriate and situates the responsibilities correctly. The policy aims to safeguard all those that come into contact with UKRI funded research, and places a responsibility on funding recipient organisations to appropriately handle and investigate any concerns raised. At the same time, DSIT is currently working to integrate appropriate safeguarding measures into the new International Science Partnerships Fund (ISPF), which has been operating since April 2023. The safeguarding approach will be a part of the ISPF strategy, which is expected to be published at the beginning of 2024 at the latest.

Funders have also been intensifying efforts to tackle bullying and harassment.  UKRI continues to facilitate a Forum for Tackling Bullying and Harassment, including Sexual Harassment, bringing together partners from funding, policy and regulatory organisations. Wellcome’s new Bullying, Harassment, Abuse and Harm policy was launched in May 2023. This recent policy review aimed to ensure that safeguarding continues to be central to their funding approach. This is as the result of an internal benchmarking assessment against the practice standards within the UKCDR ‘Guidance on Safeguarding in International Development Research’. Core changes to the policy have included specific requirements about the upholding of the rights and safety of survivors, a broadening of the forms of harm and abuse covered, and further clarity about when allegations and concerns will be shared in order to promote the safety of those who may be at risk. 

Additionally, in May 2023 Wellcome launched their new Equity, Diversity and Inclusion (EDI) policy which for the first time outlines EDI expectations and how Wellcome will handle allegations of discrimination. The policy allows Wellcome to issue sanctions where allegations of discrimination are upheld. It also outlines principles for inclusive research and the steps organisations are encouraged to take to support EDI in research environments.  

2. Ongoing efforts to strengthen training and awareness raising activities 

Training and awareness raising activities are a core part of funders’ efforts to improve safeguarding standards in the sector. There are a number of recent initiatives worth highlighting: In March 2023 NIHR held an online workshop on ‘NIHR Global Health Research Safeguarding, Ethics, IP & Assurance’, with research managers and contract offices of the relevant institutions holding NIHR Global Health research awards and contracts. FCDO continues activities around a Department-wide Safeguarding Week, that all staff have been encouraged to attend. Additionally in 2023 the number of Safeguarding Champions in FCDO’s Research and Evidence Directorate (RED) doubled, with 2 staff members in the Global Science Department volunteering for the role. This enabled more engagement, including a presentation on Safeguarding Awareness to the Department, and a slot at FCDO’s Africa Science Conference to highlight the most salient actions on safeguarding.  These include examining UKCDR research-specific guidance, discussing responsibilities with partners, and ensuring awareness of confidential reporting mechanisms for staff, delivery partners and research participants. 

Wellcome has mandatory safeguarding training in place for all staff. Wellcome launched the course for the first time in October 2022, to support staff in understanding their obligations and policies. Staff are required to consider how they identify and respond to concerns through a range of scenarios, including safeguarding of participants within funded research. A range of supplementary courses have also been developed by Wellcome, and launched in the summer of 2023, that aim to develop staff practice in specific areas of safeguarding. These include risk assessment and management, and conducting lessons-learned reviews that can support continual improvement.

FCDO are codifying their regular and bespoke safeguarding activities into an action plan with the aim of further raising understanding and inculcating a positive proactive safeguarding culture across RED and its programmes. 

3. Sustained emphasis on improving monitoring and reporting processes 

Efforts to strengthen the reporting mechanisms in place emerged from various funders, showing the sector’s willingness to improve internal and external accountability. NIHR has revised their incident reporting Standard Operating Procedure (SOP). UKRI continue to work to develop a process that will enable a streamlined reporting process across a number of non-financial reporting requirements and will enable UKRI to capture safeguarding concerns in a more standardised manner.   

Challenges and lessons

1. Monitoring and reporting processes

Funders highlighted the importance of standardising the collection of information on incidents reporting. NIHR specified the crucial role played by having a single template across all the programmes. Wellcome are currently developing a new bespoke system to further advance their ability to draw sufficient data from cases and incidents across Wellcome’s diverse range of activities (including both direct activities with people (eg Wellcome Collection) and grant funding. This will support the aim of informing wider planning and learning.

2. Awareness raising

Understanding the role of awareness raising activities was mentioned as a crucial lesson by funders. NIHR remarked on the importance of raising awareness amongst contractors and staff about NIHR Safeguarding Guidance and other useful resources such as the Safeguarding Resource and Support Hub.  

3. Resource constraints

Some funders mentioned that they have been constrained in their ability to make significant progress – and report on it. The primary challenge in undertaking further work in this area is resource constraints.

4. Data protection and barriers to information sharing

Wellcome explained that during the implementation of their research funding policies they have been engaged in discussions around the sharing of information that relates to safeguarding concerns. This work has been focussed on ensuring that barriers to the sharing of information are properly identified and addressed. They have worked to bring together organisations with an interest in data protection to help to address this sector-wide challenge. Further information is included in the case study below. 

Case study: Data protection and barriers to information sharing

In 2022, Wellcome convened a selection of funders and organisations engaged in the issue of data protection. The aim was to tackle the sector challenge in ensuring that information relating to instances of harm and abuse can be shared between institutions and funders lawfully and properly.  

In 2023, Wellcome, UKRI, Cancer Research UK, the British Heart Foundation, the National Institutes of Health Research, the Association of Medical Research Charities, and the Royal Society met with the Information Commissioner’s Office (ICO). There was productive discussion, achieving clarity on the use of legitimate interests for the sharing of such information.

During 2023 Wellcome has been developing a webinar on data management in bullying, harassment, abuse and harm (and research misconduct). This will be focussed on legitimate interests and how it impacts on information sharing. This webinar will be delivered externally to support organisations’, complainants’ and respondents’ understanding for releasing information and Wellcome’s legitimate interest in receiving that information.

Next steps

1. Continued implementation of safeguarding policies, guidance and action plans

Funders will continue to strengthen their commitment to safeguarding, and work to improve their policies, guidance and action plans. NIHR are currently working with DHSC to assess the requirements for more in-depth safeguarding training for Centre Safeguarding leads. They are aiming to implement this in 2024, offering 2 levels of training: (i) introduction to safeguarding for new starters; and (ii) in-depth and focused training for safeguarding leads. 

UKRI’s priorities in the next 2 to 5 years include strengthening their ability to respond robustly and adequately to reports, continue to improve awareness on the impacts of SEAH as well as bullying and harassment, improve data collection to better understand and monitor the problem, and work with other funders and regulators to join up policy to create system-wide change. 

2. Diversifying the research partners that are funded

Wellcome has committed to becoming an anti-racist organisation and, in line with UKCDR’s guidance^{[footnote 9]}, a central aim of their current strategy is to diversify the research that they fund. This translates to their Culture, Equity, Diversity and Inclusion goals, including:  

• by 2031, people funded by Wellcome will be more representative of the global population, able to be themselves and supported to be their best and
• by 2031, all Wellcome funded research will be inclusive in both design and practice, to help drive better science and more equitable health solutions

Wellcome is currently commissioning research on what inclusive research design and practice looks like, and launching a funding call for black British researchers.   

3. Strengthening understanding of the needs of diverse groups  

Wellcome has set a goal to becoming an anti-ableist organisation. In line with UKCDR’s guidance^{[footnote 10]}, they are working with a range of parties to take multiple views and needs into account. Wellcome staff networks are driving understanding around the needs of people with protected characteristics, and often collaborate to highlight intersectionality. Staff have formed a number of internal working groups to share and inform on best practice in relation to equity and diversity in the research they fund, including the Low-and Middle-Income country group and the Partnership Practice groups.  

British International Investment (BII)

Since our commitments to FCDO in October 2018 to tackle sexual exploitation, abuse and harassment (SEAH) in the development finance sector, British International Investment (BII) has continued to uphold high safeguarding standards amongst our staff and partners and has advanced the integration of safeguarding risk and incident management into our investment portfolio. Over the past 5 years, safeguarding has become a priority risk area for BII that we have addressed through our updated Policy on Responsible Investing (PDF, 1.2 MB), the development of a Guidance Note, the formalisation of reporting and risk management requirements, engagement with investees, the roll-out of a training programme, and the development of tools and templates. These workstreams are reported on a quarterly basis to a group of senior BII stakeholders, including the BII Board Champion on Safeguarding. 

Progress

Over the past 5 years, BII has continued its progress against its commitments in line with the Strategic Shifts. Key highlights are: 

1. Expansion of safeguarding training across investment portfolio

Drawing upon our learnings from 5 years of investee engagement and incident reports, BII developed a Basic Training on gender-based violence and harassment (GBVH) to establish core concepts and what risk and incident management entail. This Basic Training was run in August 2023 with over 100 participants from South Asia and 230 participants from Africa, and the recording has been subsequently been viewed over 200 times. In order to support investees who were further in their safeguarding management journey, we also instituted an Advanced Training in September 2023 for small groups to focus on how to improve policies, processes and incident response. This training took place in Nigeria, South Africa, India and Bangladesh, as well as 2 virtual sessions, with approximately 140 participants across all of the sessions. A core focus of the training was how to ensure a survivor-centred approach. A number of BII staff, especially ESG team members, also participated in these trainings.

This training approach also helped address one of the challenges identified in our 2022 CSSG contribution: that BII’s support to investees on safeguarding requires further capacity building and training. 

2. Development of tools and best practice support materials

In response to specific demands from our investment portfolio and the wider market, BII developed a selection of tools and templates to support the 2020 BII/EBRD/IFC Guidance Note, “Addressing Gender-Based Violence and Harassment: Emerging Good Practice for the Private Sector (PDF, 1.2 MB)”, and our enhanced training roll-out. These are publicly available through our ESG Toolkit page on GBVH.

3. Continued strengthening of internal capacity

Since 2018, BII has worked closely with expert consultants to advise on safeguarding risk and incident management in our portfolio and to help develop our internal escalation procedures. In 2019, this was formalised in an agreement with expert consultants who provide technical guidance and support to the ESG team and our investees; we renewed this as a framework agreement in 2023 for a further 3-year period. As part of this renewal, the consultants provided training to the ESG and Gender & Diversity Finance teams on risk identification and incident management with a focus on a survivor-centred approach.

4. Safeguarding risk integration into gender-lens investing strategy

A core focus of BII’s Gender Strategy has been building the field for gender-lens investing (GLI), including the development of the 2X Challenge to mobilise investment in women’s economic empowerment. The 2X Criteria considers GBVH risk as a critical factor when assessing 2X eligibility. In 2021, BII went further by specifying that investments can only qualify for 2X if they have an adequate approach to mitigating safeguarding risks or steps to introduce/improve one are incorporated into a binding environmental and social action plan (ESAP). In 2022, this approach was more clearly defined and rolled out to the ESG I and G&D finance teams, and has been piloted throughout 2023.

Challenges and lessons

While some challenges have risen and fallen over the past 5 years, like COVID-19 exacerbating safeguarding risks, others have remained constant. For example, cultural barriers to reporting, the power imbalances enabled through relatively lower representation of women in senior positions, and the gap in private sector experience in the topic are all challenges that became evident at the time of our commitment and that continue to this day.

Over the past year, some of these have moved from challenges to progress areas, while others have manifested in the following specific challenges and lessons:

1. The need for in-country and sector expertise to support on implementation and incident management and address reporting barriers

Private sector knowledge, skills and process awareness for GBVH/safeguarding risk and incident management are relatively nascent. GBVH is a sensitive and often taboo topic, and one that needs to be understood and addressed with awareness of the cultural context. As a result, in-country experts with regional and sector expertise are important for BII investees to access guidance and support needed. This has been a challenge for BII and other DFI investors in Africa and South Asia (with whom we often collaborate), and one that we are working to overcome through identifying experts across our networks, upskilling those who have more public sector experience on private sector considerations, and sharing information.

2. Data collection and analysis is challenging

While incident reporting is increasing, and we are learning through the trends that emerge, it is difficult to analyse the data as we know underreporting is rife and there are no consistent country or sector benchmarks. This will not be resolved in the short-term, but it highlights the importance of sharing information where possible in line with strict confidentiality considerations.

Next steps

1. Iterate and expand on new basic and advanced GBVH training and tools for investees as a driver of our capacity building efforts to raise baseline understanding of risk and incident management.

2. Provide proactive support to sectors and dynamics where we assume elevated safeguarding risks: based on our learnings from data gathered and incidents to date, and an assessment of where incident reports come from in our portfolio, we can identify specific sectors, investment products and power dynamics that are higher risk. We will focus on these in our risk mitigation efforts.

3. Continue to train investment and impact teams on BII’s safeguarding requirements and how to support our investees to ensure alignment and shared responsibility for this institutional priority.

The Global Fund

The Global Fund to Fight Aids, Tuberculosis and Malaria (Global Fund) is a Geneva-based financing agency that receives funding from public and private sources. It is a significant donor to health programmes in Africa, Asia-Pacific, Eastern Europe & Central Asia, and Latin-America. 5 years ago, in 2018, the Global Fund made their first PSEAH commitments to increase efforts in prevention, training, capacity-building, strengthening accountability mechanisms, and working with our governance bodies, implementing partners and suppliers to do the same. Since then, integration of PSEAH practices and a victim/survivor-centred approach across all relevant Global Fund activities has become a priority for the Global Fund, where we have adopted a zero-tolerance for inaction approach. PSEAH work today includes workstreams devoted to SEAH prevention, response-readiness, and actual response.

Progress

1. Adopting minimum standards, empowering staff, and strengthening accountability mechanisms

In 2020, the Global Fund updated its Codes of Conduct to align with safeguarding standards in the wider international development sector. These standards were further outlined in the Global Fund Child Protection Framework (PDF, 578 KB) (published June 2021), and the Global Fund’s Operational Framework on PSEAH (PDF, 562 KB) (published August 2021). At the same time, the Global Fund established a new PSEAH Coordination Unit (PCU). The remit of the PCU is to integrate a victim/survivor-centred, trauma-informed approach to PSEAH across all relevant Global Fund operations. Since 2021, the PCU has grown exponentially into a team of 9 coordinating SEAH prevention, response readiness, and actual response. In addition, a senior management-level PSEAH Steering Committee and an operational-level PSEAH Working group have been integral to embedding PSEAH practices across the organisation since their inception in 2021. In the first cycle, PSEAH training was offered to members of the Steering Committee and the Working Group, as well as people managers. Regular PSEAH training was introduced for all staff in 2022 and now forms part of the induction of new staff.

2. Consolidating a victim/survivor-centred response to SEAH

To integrate a victim/survivor-centred, trauma-informed approach to SEAH prevention and response interventions, the Global Fund has implemented various actions to support victim/survivors and relevant stakeholders across the Global Fund partnership:

In January 2022, the Global Fund hired a Victim Advocate and In-Country Support Coordinator. This position is responsible for advocating for the rights and support of victim/survivors, collaborating with investigators from the Office of the Inspector General (OIG) and an internal multi-disciplinary team to ensure a victim/survivor-centred approach is brought to each beneficiary-facing SEA, and allegation, and coordinating connection between existing PSEAH networks and Global Fund PSEAH focal points at implementer level and within Country Coordinating Mechanisms (CCM). In November 2023, the Global Fund added a second Victim Advocate and In-Country Support Coordinator.

Since September 2022, the Global Fund has additionally supported its in-country partners in their own SEAH investigations at both implementer and CCM level.  2 SEAH Case Managers oversee and support a victim/survivor-centred and trauma-informed approach to allegations of SEAH within the Global Fund ecosystem but outside of the OIG mandate. In October 2023, the Global Fund PSEAH Steering Committee endorsed a Victim/Survivor Services Protocol that defines and explains our expectations for grant recipients in facilitating victim/survivor support services. The draft Protocol, expected to be published by the end of 2023, guides Global Fund Recipients in the facilitation of victim/survivor support as articulated in the Codes of Conduct. Recognizing that our Recipients do not all have same PSEAH capacity from one to the next, the Global Fund is in the process of building a Victim/Survivor Support Services Fund (VSSF) which will be a fund of last resort that is available to grant recipients and their direct suppliers when they can demonstrate that they do not have the ability to access funds efficiently to facilitate necessary victim/survivor support.

3. Operationalising PSEAH at country level

In the previous reporting cycle, the Global Fund reported progress related to the development of a country-facing SEAH risk management approach, while our struggle remained appropriately pacing effective operationalization at country level. From December 2022 to-date, the Global Fund has successfully implemented a multi-faceted, risk-based, and impact-driven SEAH risk mitigation plan at the implementer and program level. This work will continue throughout the next grant cycle and become embedded into grant making and grant management. Specifically:

i) An Ethics Officer role with a PSEAH mandate has been piloted in Country Coordinating Mechanisms (CCM) in 15 countries. Given that the Global Fund has no in-country presence, the CCM Ethics Officers have been instrumental in raising awareness on PSEAH among key stakeholders, organising the integration of PSEAH interventions during grant making, supporting implementers of Global Fund grants to establish PSEAH focal points and networks, and overseeing SEAH risk management work (see case study).

ii) Every non-UN Principal Recipient will be assessed for compliance against minimum PSEAH and Child Protection standards as outlined in the Codes of Conduct. The assessment verifies that these standards have been integrated into implementer policies, made mandatory for staff, and cascaded from Principal Recipients to Sub-recipients and Suppliers. The assessments began in 2023 and are scheduled to be completed at the end of 2024.

iii) Principal Recipient PSEAH Capacity Assessments, aligned with similar capacity assessments undertaken by partner organisations, were initiated in 2023 for Principal Recipients in 12 priority countries (Kenya, Ethiopia, Cameroon, Tanzania, Mozambique, South Africa, Burkina Faso, Cote d’Ivoire, Indonesia, Viet Nam, Nigeria, Zimbabwe). The capacity assessments will be followed by targeted, risk-based capacity strengthening support. The remaining Principal Recipient PSEAH Capacity Assessments will be rolled out gradually, in a differentiated manner, in all countries receiving Global Fund grants.

iv) A pilot for ‘safer programming’ or integrating SEAH risk mitigation directly into grant activities, is underway in 8 countries as of October 2023 (South Africa, Guatemala, Rwanda, Namibia, Philippines, Cameroon, Kenya, Ghana) as part of the grant application process. These pilots allow the Global Fund to hone an institutional approach that will become part of our regular grant-making process. This grant-level SEAH risk mitigation work is scheduled to scale to our highest SEAH impact countries throughout the grant cycle.

Challenges and lessons

1. Implementer response readiness

The Global Fund has prioritised strengthening our victim/survivor-centred response to SEAH allegations and incidents, through specific requirements on SEAH response in Codes of Conduct, increased human resources, additional policies and procedures on SEAH response, greater coordination among specialised staff, and additional in-country support on SEAH cases. However, as many implementers are not yet confident in offering a safe, confidential, victim/survivor-centred response to SEAH allegations, our challenge is to support Principal Recipients, Sub-recipients, and Suppliers as they implement a victim/survivor-centred response to any cases of SEAH that arise and prevent any further harm in the process. Throughout 2024, we will support detection and response capacity with a series of ‘response readiness’ tools and initiatives, including training events and materials, a checklist for implementers when addressing SEAH allegations, a self-assessment for implementer misconduct reporting channels, guidance for implementers on how to conduct SEAH service mapping, a victim/survivor needs assessment form, and more.

2. Aligning and coordinating PSEAH capacity assessments with partners in the international development and humanitarian sector

In 2023 the Global Fund initiated a gradual, differentiated rollout of PSEAH Capacity Assessments of its Principal Recipients, focusing on 12 highest priority countries first. The PSEAH Capacity Assessment is aligned with capacity assessments developed by development and humanitarian partners such as the UN Implementing Partner PSEA Capacity Assessment (PDF, 275 KB) but tailored to the Global Fund context. We recognise that our in-country implementing partners often work with several different donors/partners and may, as a result, be subject to multiple capacity assessments. To lessen the burden on implementing partners, the Global Fund will recognise any capacity assessment undertaken by the UN and align our capacity-strengthening efforts to any capacity-strengthening plan put in place through such sector partner assessments when this information is made available to the Global Fund. Coordination with partners will be required to avoid duplication and allow access to existing partner data. As this type of information sharing has been challenging in the past in other areas such as SEAH case data, we are cognizant of the challenges that lie ahead but committed to working through any issues for the good of our common implementers.

3. Connecting with existing in-country PSEA networks

Consistent with the Global Fund principle of in-country ownership, the Global Fund recognises the importance of a localised approach to preventing and responding to SEAH and to working with partners in-country to ensure effective coordination. The Global Fund encourages and facilitates the use of local PSEA networks wherever available to guide implementation of PSEAH activities. Given the differences in the Global Fund’s business model, the challenge ahead lies in integrating local Global Fund focal points into existing UN-led PSEA Networks.

Case study: Building PSEAH capacity through the CCM Ethics Officer in the Philippines

After the CCM Ethics Officer joined the Philippines Country Coordinating Mechanism (PCCM) in June 2023, her role has been instrumental in building PSEAH capacity of in-country stakeholders. After working with the Global Fund’s PCU to conduct an initial program-level risk assessment and mitigation activity with implementers and Key Populations in July 2023, the CCM Ethics Officer led the drafting of a PSEAH Policy for the PCCM; initiated collaboration with the existing Philippines PSEA Task Force; and organised a series of PSEAH workshops for key populations, including sex workers, transgender people, men who have sex with men, persons who use drugs, and adolescents and young people, as well as for HIV/AIDS Peer Navigators. This work has included support for implementer updates to codes of conduct and safeguarding policies to include PSEAH and child protection provisions, support for the integration of safer recruitment processes, and introduction of mandatory PSEAH training for all staff of implementing organisations. In a setting where the Global Fund has no in-country presence, the added value of the CCM Ethics Officer in integrating PSEAH standards at country level has been an apparent and critical part in SEAH prevention and response readiness.

Next steps

The SEAH risk management approach developed in 2022 and piloted in 2023 will continue with differentiated implementation at scale in 2024 and 2025, incorporating lessons learned throughout the development and pilot periods. This includes the gradual roll out of PSEAH Capacity Assessments, followed by risk-based targeted capacity strengthening activities, over the following 3 years. In 2024 and 2025, focusing on the top ten highest SEAH risk/highest SEAH impact countries, the PCU will join up response readiness support with grant-level risk mitigation work, enabling integration of holistic PSEAH practices at the local level in the highest SEAH risk/impact countries. Combining support for organisational PSEAH capacity building, grant-level risk mitigation, and local integration with existing services and reporting mechanisms, the PCU will enable local ownership and integration of end-to-end best practices in PSEAH. The Global Fund will also continue efforts to operationalise a victim/survivor support services fund, a fund of last resort, to enable efficient and equitable delivery of necessary support services, and work to ensure that a victim/survivor-centred, trauma-informed response meets every SEAH allegation in connection with Global Fund activities. 

The CCM Ethics Officers will continue to be pivotal in coordinating and overseeing SEAH risk management work in countries, with the extension of the pilot throughout 2024 and an increased investment in their PSEAH activities.

Gavi, the Vaccine Alliance

Gavi, the Vaccine Alliance is a Geneva-based organisation which receives funding from public and private sources to finance vaccine programmes in recipient countries. Gavi is a significant donor to health programmes in lower income countries. As of June 2023, Gavi has contributed to the immunisation of over 1 billion children, delivered over 1.8 billion vaccinations through campaigns in lower income countries, and helped prevent more than 17.3 million future deaths from vaccine-preventable diseases. In 2018, Gavi made a commitment alongside the Global Fund to prevent and respond to sexual exploitation and abuse, and sexual harassment (SEAH) in its internal and external operations.

Progress

1. Establishing an Ethics, Risk and Compliance Office with safeguarding focal point

As part of Gavi’s ongoing audit of its approach to prevention of sexual exploitation, abuse and harassment (PSEAH), Gavi reviewed its entire ethics framework and consequently established the Ethics, Risk and Compliance Office (“ERCO”). The ERCO will establish a framework for PSEAH and will help to strengthen coordination and consistency of implementation of PSEAH policies and procedures throughout the Gavi teams. The framework will draw from the Inter-Agency Standing Committee (IASC) 6 Core Principles and the Common Approach to Protection from Sexual Exploitation, Abuse and Harassment but also be tailored to Gavi’s programmes and operations. Gavi’s audit also surfaced areas to target for improvement, such as strengthening mitigating measures in the secretariat and enhancing measures to prevent, detect and resolve incidents relating to inappropriate behaviour by implementing partners and their employees in-country.

2. Empowering partners to develop and implement PSEAH programmes

Gavi has introduced new programme funding guidelines (PDF, 4.4 MB) that explicitly encourage the use of Gavi funds to design and implement policies and measures to respond to PSEAH. In 2022, Gavi partnered with the Centre for Disease Control (CDC) to conduct implementation research on safety of health workers and measures to take to protect health workers.  The study will take place in Zambia and results are expected by Q3 2024.  Some countries are starting to use health system strengthening grants to implement PSEAH measures (Haiti and Papua New Guinea). Gavi has also partnered with the Global Women’s Institute to roll out trainings to Gavi and Alliance Partners including modules on PSEAH.

3. Expanding and strengthening changes to policies, procedures and training

Over the past 5 years, Gavi has updated its Respectful Behaviour Policy and rolled out training for the Gavi workforce (including staff, consultants, interns and secondees). An e-learning module on this topic is required for all new joiners to Gavi during onboarding. Gavi’s HR team has additionally rolled out enhancements to Gavi’s recruitment process designed to demonstrate Gavi’s commitment to a zero tolerance approach to SEAH, including background checks and required self-disclosure of SEAH misconduct by applicants. Gavi continues to review and consider how to tailor trainings to Gavi’s operations and people and promote a culture of speaking up within Gavi.

4. Expanding PSEAH commitments in implementing partner agreements

Gavi has continued to build on its templates with implementing partners to reinforce Gavi’s commitment to PSEAH by requiring Gavi partners to agree to a code of conduct and other terms that reflect Gavi’s policy of zero tolerance with respect to inaction on SEAH and anti-retaliation against whistleblowers. Gavi continues to seek to improve its templates with Alliance Partners to include the commitment to zero tolerance for inaction and support for victims.

Challenges and lessons

1. Reporting of SEAH incidents in Gavi-supported countries

Gavi’s primary support for countries is through the purchase of and delivery of vaccines in implementing countries, usually through Gavi’s core Alliance partners, including UNICEF, WHO and the World Bank. Gavi is therefore typically removed from direct involvement in the delivery of vaccines to recipients in countries, which makes it more difficult to inform victims and witnesses of SEAH about Gavi’s reporting channels and commitment to providing support to victims. Gavi’s ability to detect and respond is also limited because Gavi does not have a right to access information about SEAH incidents reported to its Alliance partners or the ability to investigate without the explicit consent of the partner, which limits Gavi’s ability to respond directly and swiftly in the event there is an incident of SEAH in a Gavi-funded programme administered in country by an Alliance partner.

2. Commitment to PSEAH at the country level

While Gavi promotes PSEAH at the country level, including through providing training and financial support for SEAH programmes, Gavi does not directly control countries’ policies and approaches. Gavi is actively considering new approaches to embedding SEAH within Gavi country programmes.

3. Acting on the need for stronger internal coordination

Gavi’s implementation of its commitments to PSEAH requires input from many teams in the Secretariat, including but not limited to the Executive Office, Human Resources, Legal, Investigations (which maintains the hotline and web reporting channels, Risk (now the Ethics, Risk and Compliance Office), Country Programmes and Health Systems Immunisation Strengthening teams and Gavi will continue to take a holistic approach to PSEAH. Building on these efforts, the establishment of ERCO, which includes a safeguarding mandate, will help to strengthen coordination and consistency of implementation of PSEAH policies and procedures throughout the Gavi teams.

4. Culture transformation journey efforts

Gavi has started a multi-faceted, multiyear culture journey, deploying a robust culture diagnostic to identify the strengths to amplify and the weaker areas to address in the current culture. A holistic and systemic approach is being followed that will embed a target culture determined by the leadership team across the organisation to create sustainable change. Gavi is striving to develop a culture that supports our critical goals, and enables every employee to feel valued, respected and heard. As part of this commitment to an inclusive workplace culture, mandatory unconscious bias training has been rolled out to all employees, consultants and interns in Q4 2023. An in-person programme will be delivered in 2024 to complement the web-based learning. To ensure that new employees receive this training, Gavi is designing a new Onboarding programme to begin in 2024, and this mandatory unconscious bias training will be embedded into it. Through this training, the aim is to enhance awareness, empathy, respect, inclusion and continue the journey to ensure fair decision-making at all levels ultimately to create a culture of inclusion at all levels across the Secretariat.

Next steps

Gavi plans to further build on its work in the coming years by continuing to evolve its policies and procedures. Gavi’s Chief Ethics, Risk and Compliance Officer (CERCO), with input from other relevant stakeholders, is developing a Prevention of Sexual Exploitation, Abuse and Harassment (PSEAH) Framework. The Framework will reiterate Gavi’s commitment to zero tolerance for inaction with respect to incidents of SEAH and set forth the roles and responsibilities for implementation and oversight of policies and procedures reinforcing Gavi’s commitment, both with respect to countries and internal to the Secretariat. The Framework will also act as a blueprint for further action by Gavi with respect to:

1. Prevention of SEAH

The Framework will set out policies around Gavi identifying, escalating and tracking safeguarding risks. The Framework will provide guidelines about Gavi conducting capacity and risk assessments before making funding commitments that include an assessment of safeguarding risks to be included on Gavi’s risk register. Gavi will continue to work with its partners to evaluate its procurement, onboarding and recruitment processes to ensure appropriate due diligence of applicants to provide appropriate and up-to-date training on Gavi’s commitment to the prevention of SEAH in onboarding.

2. Reporting mechanisms and response

The Framework will provide additional references for the reporting and investigation of complaints, including for the support of survivors/victims of incidents of SEAH and providing retaliation to whistleblowers. The policy will include sections on available disciplinary and administrative sanctions in response to incidents of SEAH.

3. Monitoring, accountability and transparency

The Framework will set out monitoring, compliance and assurance measures. The Framework will also provide guidance about the appropriate circumstance for referring allegations of SEAH to competent national authorities, taking into account the safety and rights of the victim/survivor.

The International Federation of Red Cross and Red Crescent Societies (IFRC) and British Red Cross (BRC)

Following the Safeguarding Summit hosted by DFID (now FCDO) in 2018, BRC and FCDO published a pledge in 2019 to prevent and respond to sexual exploitation, abuse and harassment (SEAH) in humanitarian action at the 33rd International Conference of the Red Cross and Red Crescent in Geneva, reiterating the Movement’s long-standing commitment to preventing and responding to SEA. The pledge has been signed by each of the Canadian Red Cross Society, Austrian Red Cross, Irish Red Cross Society, Spanish Red Cross, Italian Red Cross, Spain and Australia. Progress reporting may be submitted periodically, and a composite final report submitted to the 34th International Conference in 2024.

Progress

1. Organisational capability

The last 5 years has seen a massive investment in increasing awareness and operationalisation of institutional commitments to zero tolerance for SEAH against those we serve or our own personnel and volunteers. Activities include:

• the adoption of a set of Movement-wide commitments for community engagement and accountability which explicitly provide for the integration of do no harm approaches into needs assessments and planning
• embedding safeguarding risks in the risk logs of every IFRC delegation and mandatory requirement for child safeguarding risk analysis for all new IFRC programmes and emergency responses
• delivery and uptake of mandatory PSEAH training for all personnel, redrafting of job descriptions to better articulate safeguarding responsibilities of senior managers including Heads of Delegations
• institution of an accessible central complaint mechanism (Integrity Line) and significantly enhanced regional investigation capacity
• a new legal framework between Red Cross and Red Crescent National Societies and IFRC establishes a single standard of Safeguarding screening, vetting, training and retention requirements to ensure emergency surge actors from across the IFRC network who deploy under the auspices of IFRC do so safely, understanding their duty to do no harm and the consequences of any breach

2.  Organisational capacity

The IFRC has additional dedicated safeguarding staffing at their headquarters in Geneva and in some high-risk contexts including Afghanistan and Asia Pacific Region. The BRC has a comprehensive safeguarding structure established, which comprises the Safeguarding Advice Team, Safeguarding Development Team and the PSEA Team. A strategic lead has been in post since July 2021. The Safeguarding Advice Team began in 2019 and has 7 Safeguarding Advisers that provide safeguarding advice to the organisation. The Safeguarding Development team has been restructured in 2022 with increased capacity and is working on a Safeguarding Action Plan to improve our own systems. The PSEA Team focuses on strengthening safeguarding (primarily PSEA) with BRC’s partner National Societies and Movement actors, including funding safeguarding strengthening programmes and/or providing technical and accompaniment support for National Society focal points in 8 countries^{[footnote 11]}. Through a combination of IFRC and partner National Society^{[footnote 12]} support, 38^{[footnote 13]} National Societies now have a PSEA policy which has been approved by both their Board and the IFRC whilst a further 22 National Societies have PSEA Policies under development^{[footnote 14]}. 36 ^{[footnote 15]}National Societies have a Child Safeguarding policy which has been approved by both their Board and the IFRC whilst a further 12^{[footnote 16]} have Child Safeguarding Policies under development.

3. Partnerships

IFRC has committed to the provision of additional funding of up to $50,000 per application to National Societies within the Capacity Building fund for Safeguarding initiatives. Organisational Assessment Kits now explicitly include a landscape review on Safeguarding resulting in integrated action plans with safeguarding components being developed in a diverse range of National Societies including Iceland, Uganda, Sierra Leone and Malawi. A Safeguarding Self-Assessment tool with 16 standards is being rolled out across a number of National Societies to enhance engagement, understanding and capacity and anticipated to be rolled out in delegations going forward. As of July 2023, the BRC expects all partner National Societies (including any National Society recipients of FCDO funding) to meet minimum operating standards for PSEA or be on a pathway towards meeting safeguarding minimum standards.

4. Enhanced accountability and transparency

The BRC is a member of the SEAH Harmonised Reporting scheme which aims to increase transparency on SEAH. The IFRC transparency initiatives include regular Office of Internal Audit and Investigation (OIAI) hosted quarterly meetings with key stakeholders to openly discuss allegations, investigations, and integrity action plans. Most significantly in addressing impunity, all IFRC Personnel against whom investigations regarding Sexual Exploitation & Abuse have been substantiated have been dismissed and non-identifying details regarding the incident outcomes have been shared with personnel and donors alike. IFRC has publicly committed and notified all personnel-including those on emergency surge-that substantiated complaints of SEAH will result in their names being shared with the Misconduct Disclosure Scheme (MDS) and in 2022 both withdrew a number of offers of employment following MDS checks and ended a professional relationship with an individual who refused to participate in the scheme. Annual Reports on Harassment Cases compiled by the Human Resources Management Department (HRMD) are shared with all staff providing non identifying data on the number and typology of cases reported to IFRC and quarterly updates are provided in several regions by OIAI to enhance accountability, build trust and support the development of a Speak Up culture.     

Challenges and lessons

There is much work to do to develop organisational culture across the IFRC network that effectively safeguard the people and communities we support, as well as volunteers and staff. Some specific challenges in this regard are outlined below.

1. Accountability frameworks at odds with institutional PSEAH requirements

The jurisprudence of the ILO Administrative Tribunal (ILOAT) requiring that guilt be established “beyond a reasonable doubt” instead of through “clear and convincing proof”, as is more common to administrative cases, hampers efforts to sanction employees of international agencies including IFRC against whom SEAH allegations have been substantiated. The higher evidentiary standard does not account for the more likely circumstantial nature of evidence since occurrences of SEAH are usually in private, out of sight of witnesses and lacking definitive corroboration (unlike the audit trails more usually found in financial/corruption misconduct). This potentially may result in organisations being simultaneously vulnerable to actions by victims for breach of duty of care or liability for the behaviour of their staff (which may/not also be criminal) and by perpetrators for breach of their employment contract. In either scenario organisations may also risk losing funding from donors enforcing PSEAH conditionalities. Similarly, despite the vast majority of donors requiring meaningful vetting and screening of personnel by aid agencies, national employment or data protection legislation of many of the same donors may hinder utilisation of schemes such as the Misconduct Disclosure Scheme which to date has successfully prevented several hundred hires and potentially significant harm to and amongst highly vulnerable populations including children.  A more informed and joined up approach is required if organisations are to be enabled to effectively fulfil their duty of care to those they serve as well as their own personnel and the trauma of victims is to be prevented or appropriately responded to.

2.Unpredictable funding

Whilst recognising that Safeguarding is core to what we do, contributions to core funding to enable sustained investment in technical capacity and delivery remain unpredictable or highly constrained. The utilisation of emergency response funding to support safeguarding initiatives necessarily results in short term interventions which, whilst immediately valuable, may not translate into sustained change or the integration of key prevention action within subsequent recovery planning. The opportunities to access pooled funding for Safeguarding initiatives remain very limited despite common concerns and approaches at interagency level leading to multiple piecemeal interventions rather than potential economies of scale over time. 

3. Embedding safeguarding at outset of emergencies and programmes

The risks of SEA against children and adults by humanitarian workers are heightened in situations of crisis, conflict and forced displacement. Groups most at risk of SEA eg women, children and people with disabilities are recognised as being at even more at risk in emergency situations. The risks are exacerbated when humanitarian organisations have not yet established and operationalised safeguarding policies, structures, systems and culture. This underlines the need for upscaling support for safeguarding institutionalisation and integration of safeguarding Standard Operating Procedures (SOPs) to disaster preparedness, management and contingency plans, as well as ensuring that safeguarding is actively addressed at the early stage of emergency response operations.

Next steps

IFRC will lead work on Safeguarding Self Assessments and associated capacity building with multiple National Societies to support and assure the mainstreaming of prevention and response in the planning, delivery and support to those we serve. A multilevel Safeguarding training and capacity building plan is in development prioritising senior and other managers and HRMD staffing to embed operationalisation of Safeguarding commitments and enhance understanding and identification of associated risks. Increasingly visible Leadership Commitment to Safeguarding and cultural change will continue to be amplified and promoted. This includes regular messaging and peer to peer learning in fora such as the Global Management Meeting where Heads of Delegation share their experience and learning of successfully navigating Safeguarding hazards and risks. 

The BRC will work with partner National Societies^{[footnote 17]} (more than 10% of National Societies in the IFRC network) to help ensure all partners meet minimum standards for safeguarding. A comprehensive programme of support (value GBP 1 million) has been agreed with 15 partners in 2024, representing a significant contribution to the IFRC’s Global Safeguarding Action Plan (2022 to 2025).

Annex A: Reports of cases

Each year the CSSG report includes an overview of reporting from summit signatories. The aim is to illustrate progress being made and to encourage the sector to publish more SEAH data and analyse the trends and implications in the interests of transparency, accountability and better prevention and response.

1. Donors  

Donor Technical Working Group (TWG) members reporting case numbers this year remains constant at 10. These members have systems in place to enhance internal reporting and to encourage reporting from implementing partners.  Donors not listed below are not yet able to share data but continue to explore the potential to do so.  

Australia, Canada, Japan, Sweden and Switzerland have experienced upward trends in caseloads over the last year, with the US, the UK, the Netherlands, Finland and Germany levelling out or with a slight drop. It remains difficult to compare caseloads year on year, but important to monitor reporting as a reflection of how systems work or face challenges (internally and through partner reporting systems) to demonstrate increased evidence and accountability, and to identify areas that require support.  

Over the past 5 years a few reporting trends have been noted by Donors. The UK initially saw a significant increase from 2018 year on year of external cases being reported to FCDO, but since 2021 to 2022 there has been a decrease. This could be attributed to the UK decreasing its aid portfolio over the past couple of years. In Australia, there have always been more reports involving adult than child survivors, except for 2018 to 2019 when the PSEAH policy launched. Numbers of cases involving children have since remained relatively constant, with adult cases increasing annually. This could be attributed to better awareness of SEAH and improved reporting mechanisms. Canada has seen an increase in the number of cases, noting that the majority of SEAH reports are from medium to large organisations (30 to 100+ employees). A large portion of reported cases took place in Sub-Saharan Africa and in the Middle East: this is where many of Canada’s international development programming is implemented, increasing the risk and the likelihood of SEAH cases. Overall, there is also a concentration of donors in these regions, which could have led to greater SEAH oversight, including reporting mechanisms. An overwhelming majority (90%+) of victims/survivors were identified as women. Japan noted an increase in cases since COVID restrictions lifted and the Netherlands concurs with SEAH professionals in the aid sector that SEAH incidents are likely grossly under-reported despite the work already done. The US saw a sharp increase (146% from FY 2018 to FY 2020) in the first years as awareness increased which has now levelled out. 

The tables below provides more detail by country. The final section for each country gives a brief idea of the support provided to survivors and victims.  The summary table at the end captures trends in numbers.  

For all countries data covers 1 September 2022 to 1 September 2023 unless stated otherwise.

Australia

Number of external reports:

External: 113 

Category	Number
Sexual exploitation (child)	Less than 5
Sexual abuse (child)	18
Total	20
Sexual exploitation (adult)	10
Sexual abuse (adult)	16
Sexual harassment (adult)	67
Total	93

Internal: less than 5 

Outcome: 

Note: systems do not capture multiple outcome types ie perpetrator arrested and strengthened internal systems. Only most significant outcome entered.

Category	Number
Substantiated	58
Unsubstantiated	9
Deemed out of scope	17
Still to be determined	29

Category	Number
Arrested	Less than 5
Counselled and/or reprimanded	6
Employment terminated	23
Resigned	10
Perpetrator unable to be identified	Less than 5
Suspended	Less than 5
Other	10

Disaggregated data: 

Open external notifications: 26

Child/adult alleged victim:

Category	Number
Child	Less than 5
Adult	22

Type of implementing partner reporting cases:

Category	Number
Commercial supplier	8
Non-governmental organisation	6
Other	6
To be determined	Less than 5
Academic institution	Less than 5
Individual contractor	Less than 5

Status of alleged perpetrator:

Category	Number
Downstream partner	11
Department of Foreign Affairs and Trade commercial supplier	Less than 5
Managing contractor	Less than 5
Other partner	5
To be determined	Less than 5

Closed external notifications: 87 

Child/adult alleged victim:

Category	Number
Child	16
Adult	71

Type of implementing partner reporting cases:

Category	Number
Commercial supplier	22
Non-governmental organisation	40
Academic institution	7
Partner government	Less than 5
Other	7
To be determined	10

Status of alleged perpetrator:

Category	Number
Downstream partner	53
Department of Foreign Affairs and Trade commercial supplier	7
Managing contractor	10
No relationship	Less than 5
Other partner	Less than 5
Partner government	Less than 5
To be determined	12

Trends noted in last 12 months with possible explanations where relevant 

• rise in external cases
• perpetrators/alleged perpetrators are typically employed by or associated with downstream partners
• this year, majority of allegations are found to be substantiated. For allegations that are substantiated, the termination of the perpetrator’s employment remains the most common outcome

Where the victim/survivor is known, counselling services were the primary support offered to victim/survivors.

Canada 

Data covers January 2022 to September 2023. Data included from January 2022 to avoid a gap in reporting periods, as last year’s data covered January 2021 to December 2021.

Number of external reports:

Category	Number
Sexual exploitation and abuse	36
Sexual harassment	14
Other	5

Outcome:

Category	Number
Closed	42
In progress	12
Dismissed	1

Category	Number
Substantiated	24
Unsubstantiated	18
Disciplinary action (of various degrees)	24

Disaggregated data:

Sex/gender of alleged victim:

Category	Number
Male	Less than 5
Female	48
Unknown	Less than 5

Child/adult alleged victim:

Category	Number
Under-18	13
Adult	36
Unknown	6

Trends noted in last 12 months with possible explanations where relevant

Double the cases reported in comparison to any of previous 3 years. Consistency in disaggregated data including high number of cases from projects in Africa and the Middle East and evidence of disparities in the gender of victims/survivors and perpetrators. 

2023 numbers seem consistent with 2022’s. However, a rise in SH and sexual misconduct cases that do not qualify as SEA. Likely due to awareness raising activities to encourage reporting.

The responsibility of victim/survivor support is with funded partners. Based on received case reports, the more commonly administered types of services include psychosocial and medical accompaniment for survivors.

Finland

Number of external reports:

Category	Number
Sexual exploitation and abuse	Less than 5
Sexual harassment	Less than 5

Outcome:

Category	Number
Substantiated	Less than 5
Unsubstantiated	Less than 5
Ongoing	Less than 5

Disaggregated data:

Sexual harassment:

Category	Number
Adults	Less than 5
Staff	Less than 5

Germany (GFFO)

Number of external reports:

18 total: 

Category	Number
Sexual exploitation	5
Sexual abuse	2
Sexual harassment	6
Safeguarding (children’s rights violations)	5

Outcome:

Category	Number
Open	14
Closed	4

Disaggregated data:

Category	Number
Non-governmental organisation	14
International organisation	4

Trends noted in last 12 months with possible explanations where relevant

Case levels have remained fairly stable since 2020 to 2021.

Japan (JICA) 

Data covers April 2022 to March 2023.

Number of external reports:

Category	Number
External	7
Internal	Less than 5

Outcome:

Category	Number
Substantiated	Less than 5
Unsubstantiated	7

Outcomes included: staff disciplined, discontinuation of training and scholarship, general warning statement issued to consultants (per victim/survivor’s request, instead of warning a specific perpetrator)

Disaggregated data:

Sex/gender of alleged victim: 

Category	Number
Male	0
Female	5
Unknown	5

Age of alleged victim:

Category	Number
Adult	6
Child	Less than 5
Unknown	Less than 5

Type of implementing partner reporting cases: 

Category	Number
Private sector	Less than 5
Foreign government	Less than 5
No implementing partner involved	Less than 5
Unknown	Less than 5

Status of alleged perpetrator: 

Category	Number
Staff	Less than 5
Implementing partner	5
Training program participant	Less than 5
Unknown	Less than 5

Trends noted in last 12 months with possible explanations where relevant

The number of substantiated cases remains at the same level as the previous years.

Several SEAH reporting mechanisms: Staff can contact peer counsellors within JICA, professional counsellors (with option for complainant to report to JICA), JICA’s HR Hotline or whistleblowing line. Externals can contact Ethics Administrators or email the SEAH reporting address.

Netherlands

Number of external reports:

Total 19: 

Category	Number
Sexual exploitation and abuse	13
Sexual harassment	6

Outcome:

Category	Number
Open	2
Closed	17

Registering disaggregated data but not sharing this more widely at this time.

Trends noted in last 12 months with possible explanations where relevant

Concerned that there hasn’t been an overall increase in reports and still very few relating to the UN, which could be due to uncertainty over when to report directly to the UN.

Most implementing partners clearly state that a victim/survivor centred approach is being applied and that victim support is being offered, most commonly psychosocial support. Noted that not all victims want to accept victim support when offered, for various reasons.

Sida/Sweden

Number of external reports:

Category	Number
External	51
Internal	Less than 5

Switzerland

Number of external reports: 19

Outcomes:

Category	Number
Substantiated	9
Unsubstantiated	2
Ongoing	8

Disaggregated data

Sex/gender of alleged victim: all 19 cases female 

Child/adult alleged victim: less than 5  

Type of implementing partner reporting cases:

Category	Number
International non-governmental organisations	14
Multilaterals	Less than 5
Non-governmental organisations	Less than 5

Status of alleged victim/survivor:

Category	Number
Beneficiaries	5
Aid workers	Less than 5
Other (victim status)	10

Status of alleged perpetrator:

Category	Number
Implementing partners	16
Subcontractor staff (perpetrator status)	Less than 5

Trends noted in last 12 months with possible explanations where relevant

Numbers increased again. Pro-active immediate reporting from partners.

UK 

Data covers August 2022 to August 2023.

Number of external reports:

Category	Number
Sexual exploitation and abuse	77
Sexual harassment	42
Total	119

Outcome:

External reports:  

Status of allegation: 

Category	Number
Cases ongoing	80%
Cases closed	20%

Outcomes of closed cases: 

Category	Number
Disciplinary action	29%
Criminal referral	20%
Allegations not upheld/no evidence	17%
No further action	17%

Partner (ie updated Safeguarding Policies or training): 17% 

Internal reports: 62 cases

Disaggregated data

External reports: 

Sex/gender of alleged victim:

Category	Number
Female	99%
Male	1%

Child/adult alleged victim:

Category	Number
Child	23%
Adult	77%

Type of implementing partner reporting cases:

Category	Number
Civil society organisation	45%
Private sector	13%
Multilateral	13%
Recipient government department	8%
Arm’s-length body	2%
Other	19%

Trends noted in last 12 months with possible explanations where relevant

There has been a fall in the number of external reports received this year. FCDO streamlined its programme portfolio during 2022 to 2023. 

The number of internal cases reported has risen which suggests rising staff confidence that when concerns are reported they will be looked into and that disciplinary action, up to and including dismissal, is taken when allegations are upheld.

For external cases the responsibility for survivor support sits with partners. The most common types of supports offered include medical, psychological and social supports. In some cases it is also appropriate to provide support for family members.

USA (USAID) 

Data covers 1 October 2022 to 30 September 2023.

Number of external reports:

112 reports: 

Category	Number
Sexual exploitation and abuse	75
Sexual harassment	10
Both sexual exploitation and abuse and sexual harassment	27

Outcome

In various states.

Disaggregated data:

Child/adult alleged victim:

Category	Number
Involve children	30.4%
Adults	55.4%
Unknown	14.3%

Type of implementing partner reporting cases:

Category	Number
Civil society organisations (grantees, contractors)	69%
Sub awardees	21%
Involve multilateral organisations	10%

Trends noted in last 12 months with possible explanations where relevant

Although no increase in number of reports, the quality of the reporting and data has improved, including more complete information around survivor support and investigative actions.

Where the information is known, survivor support is provided 41% of the time, and most often includes psychosocial support (provided in 41% of those cases).

Overview: total number of external SEAH reports since 2020 to 2023

The numbers in the final column reflect those in the country tables above. 

Donor	2020 to 2021	2021 to 2022	2022 to 2023
Australia	61	86	113
Canada	No data	15	55*
Finland	Less 5	Less than 5	Less than 5
Germany	19	20	18
Japan	Less than 5	Less than 5	7
Netherlands	No data	28	19
New Zealand	Less than 5	No data	No data
Sweden	38	42	51
Switzerland	14	10	19
UK	214	140	119
USAID	No data	109	112

2. United Nations

The UN publishes data on SEA allegations against all UN staff and related personnel, non-UN personnel working for implementing partners and non-UN international forces authorized by Security Council mandates in real time. Since 2018, reports of cases have increased which shows an increased trust in reporting, with significant increases in allegations involving non-UN personnel working for UN implementing partners.

Below is a snapshot of the annual trends:

• in 2022, 243 allegations of SEA related to UN staff and affiliated personnel were received across the UN system, and 291 allegations relating to personnel of implementing partners not under the authority of the UN were reported
• 79 allegations were reported in peacekeeping and special political missions in 2022, compared with 75 allegations reported in 2021.This is consistent with the average of 71 allegations per year over the past 10 years. 116 identified victims were associated with these allegations, of whom 90 were adults and 26 were children, compared with 189 victims identified in 2021. A total of 115 perpetrators were associated with the allegations recorded in 2022, 46 of which involved 61 individual paternity and child support claims
• in 2022, there were 18 allegations of sexual abuse of a child, compared with 25 allegations in 2021
• the majority of perpetrators, if not all, are male and most victims/survivors of SEA are female

3. International financial institutions (IFIs)

Reporting of cases: Compared to previous years, IFIs have observed a greater number of formal complaints regarding their staff members, including an increase in official requests to investigate psychological harassment claims, which reflects a growing appreciation of the spectrum of harassment. The table below, based on a sample of one IFI, illustrates how the different types of cases have increased over time. 

Category	2020	2021	2022	2023	Grand total
Discrimination and harassment	15	11	26	72	124
General inquiry	0	0	0	8	8
Integrity violations	0	0	0	1	1
Other misconduct	0	0	0	10	10
Performance management	3	9	4	0	16
Retaliation	1	0	2	1	4
Sexual harassment	0	1	2	4	7
Workplace incivility	19	35	24	30	109
Grand total	38	56	58	126	279

IFIs provide reporting on SEAH (PDF, 6.7 MB) to track and measure their cases over time. IFIs have also been advancing their approaches to strengthen reporting and handling of SEAH incidents and allegations arising from IFI-financed projects, with an emphasis on survivor-centred responses, alignment with national laws, and close coordination with project co-financiers where applicable.

4. UK non-governmental organisations (represented by Bond)

Bond’s recent safeguarding survey compared the number of reported safeguarding cases to a year ago. 57.5% of respondents reported that the number of incidents had remained the same (it was 59% in Bond’s 2022 survey data); 32.5% of respondents stated that their reported incidents had increased (in comparison to 27% from last years’ survey); and 7.5% stated that their reported incidents had decreased (14% in 2022). 

In comparison to 5 years ago, 57.5% of survey respondents reported that they had seen an increase in reported incidents. Raising safeguarding awareness is supporting survivors to report. Only one organisation shared that they had received less reports than they did pre-2018 with the remaining organisations (40%), suggesting that the number of reported incidents had remained the same.  

40% of respondents do not report safeguarding incidents publicly at present. The remaining respondents either publish the number of incidents via their annual report, on their own website or share the information publicly in other ways. 

Some organisations (55% of survey respondents), believe that there is underreporting in their organisations i.e. that they are receiving less reports than the number of safeguarding incidents that they think are taking place in their organisation. 

When asked whether organisations had seen any changes in trends of the safeguarding incidents reported, the majority (85%) reported that they had not seen any changes in the types of cases received. Bond members mentioned in our 2023 survey an increase in SEAH cases which organisations believed was due to awareness raising and training.  

37.5% of respondents felt that they would like to report publicly but would need guidance or a standardised approach to do so.  

5.UK private sector suppliers (represented by the Safeguarding Leads Network)

The majority of respondents report that the level of reporting of safeguarding concerns has stayed the same in the last 12-month period: A smaller number state that reporting has reduced while a larger number either state that reports have increased or do not have access to this information.

Some organisations are addressing under-reporting by working to enhance their existing reporting mechanisms and internal procedures and some have introduced new initiatives to make reporting more accessible to communities including introducing contextualised reporting mechanisms. Some organisations also spoke of integrating reporting mechanisms in training sessions and providing training for leadership and showed a willingness to create a community of practice around reporting. 

Most respondents to the survey cited the Employee Assistance Programme and provision of emotional and psychosocial support for employees who raise safeguarding concerns. Some organisations also referred to local support through community systems via traditional leadership groups and other culturally appropriate systems.

Collecting systematic and consistent data across the sector remains difficult. Respondents continue to report the following (in descending order of respondent numbers) 

• lack of uniformity across the sector on definitions, terminology, parameters and lack of sector-wide guidance
• concerns about reputational risk, data protection issues, confidentiality, legal implications and potential loss of funding are amongst reasons for reluctance to share information
• a culture of data-sharing on safeguarding is not yet embedded across the private sector
• many member organisations have multiple departments (not all international development) and so do not have a uniformity of reporting or sharing data

6. Research funders

Collecting harmonised and aggregated data across the entire international development research sector remains a challenge as there is currently no standardised approach to reporting cases or collection of safeguarding data across all UK research institutions.

In general, investigation of cases is the responsibility of research institutions rather than funders. However, most research funders’ policies stipulate that cases should also be reported to them, to ensure they are aware of ongoing cases and investigations. Some funders have detailed internal reporting mechanisms in their policies, whilst others are in the process of establishing them as they implement their safeguarding policies and plans.

7. British International Investment

While safeguarding has been a requirement in BII’s Code of Responsible Investing since 2012, in 2020 we revised our legal agreements across all investment products to include greater detail and specificity on safeguarding definitions and requirements to report incidents to BII. From a baseline of 9 incidents reported in the July 2019 to July 2020 period, we have seen year on year growth: a positive sign that workers and community members trust in the reporting mechanisms and that our investees are aware of the importance of escalating these incidents.  

For the period under review, July 2022 to July 2023, BII became aware of 90 incidents within our portfolio, of which 15 were categorised as severe, and 75 of lower severity. We have noted an increase in the number of safeguarding incidents reported: in the previous review period we recorded 72 incidents between July 2021 and July 2022. This increase is due to improved reporting as a result of the increased outreach and awareness raising with investees, as well as the larger number of new and repeat investees falling under our investment and legal agreements that include safeguarding reporting requirements. All of these events have been treated in line with BII’s Safeguarding Incident Management Process. In all cases, BII ensured that the investee was proactively offering survivors access to support services. 

BII has commissioned third party independent support in reviewing safeguarding incidents management, risk classification and safeguarding activities. In particular, the consultant is supporting the review of cases and development of recommendations and tools, delivered training, and refined the incident assessment criterion used to determine the level of severity of safeguarding incidents. 

8. The Global Fund

The first allegations of SEAH were received by the Global Fund in 2019, which resulted in a published investigative report with substantiated findings in 2021. Since then, we have received 64 SEAH-related allegations, with a sharp increase in complaints noted in 2023. Twenty one of the 64 complaints were converted into OIG cases, and the majority of the remainder were referred to other agencies or departments within the Global Fund, such as the Ethics Office’s PCU, merged with existing allegations, or logged for information.

Since 2021, the OIG has closed 14 cases after preliminary investigation, published an additional 3 reports after full investigation, and there are 4 active investigations ongoing. Most of the 34 allegations received between October 2022 and September 2023 involved a mix of sexual misconduct typologies: sexual exploitation, abuse, and/or harassment, rather than being “clear cut” cases falling into just one category. Most allegations received in 2023 involved implementer staff and/or volunteers as victim/survivors.

Through reported cases, it was observed that certain Global Fund activities may involve heightened risks of sexual misconduct, such as peer educator programs, as well as training workshops and group events that involve overnight stays and shared accommodation for the attendees. Another recurring dynamic noted through recent allegations is workplace sexual harassment which is rebuffed and leads to subsequent bullying and intimidation.

OIG has observed that a number of SEAH incidents are not adequately responded to by implementers in a timely fashion. This lack of adequate response is a cause for broader concerns of under-reporting. However, PSEAH outreach activities do appear to be contributing to an increased number of allegations reported to the Global Fund and its implementers in the past year.

From 1 October 2022 to 30 September 2023, the OIG finalised 5 SEA investigations and oversaw 3 implementer-led investigations. OIG referred 18 allegations to the Secretariat, for case management or further action. For SEAH cases referred to the Ethics Office by OIG, PCU case managers work with Global Fund implementers to address SEAH allegations that fall outside of OIG’s mandate.

The Global Fund’s Code of Conduct for grant recipients requires them to facilitate victim/survivor support services in SEAH cases. In the past year, victim/survivor support was offered in cases where a victim/survivor was identified and consented to receiving support.

The types of support most typically provided included:

• safety and security: such as compensation for lost stipends as a result of SEAH that impacted access to basic needs, creating or exacerbating safety concerns
• medical and psychosocial support: counselling and medical services for victim/survivors

We found that most victim/survivors do not want to report the matter to local authorities due to fear of retaliation and/or stigmatization. There is also fear of arrest, especially among men who have sex with men and commercial sex workers, should they report an incident to the police, because in certain contexts they are regarded as being engaged in illegal activities. So far, this has precluded the facilitation of access to a criminal remedy in such cases.

9. Gavi, the Vaccine Alliance

There were 2 reports (one external, one internal) in the period from 1 August 2022 to 31 July 2023, an increase from zero reports in the previous period. The internal report was prompted following training Gavi had conducted on the Respectful Behaviour Policy, as advised by the reporting person. In each reported instance, the alleged victim was an adult female and the alleged perpetrator was an independent contractor. One report was investigated and resulted in insufficient evidence of breach of Gavi’s policies. The other report was not investigated to respect the alleged victim’s wishes but the alleged perpetrator was reminded about the behavioural standards expected and that Gavi had a zero tolerance approach to this type of behaviour.

Gavi has a number of informal and formal reporting channels for incidents of SEAH. Under Gavi’s Respectful Behaviour Policy, employees, secondees, interns and consultants may report incidents of SEAH in connection to their work for Gavi to line managers, HR business partners and Staff Council and/or Gavi’s Ombudsman. Reports may also be made formally by submitting a report to HR, which will be followed by a preliminary assessment and fact-finding investigation, if required. A disciplinary process could then follow, in accordance with Gavi’s Investigation and Disciplinary Procedures. Reporting by third parties or by Gavi employees, secondees, interns and consultants may also be made to the Managing Director of Audit and Investigations via the Whistleblower and Ethics reporting web portal or telephone hotline. There is a link to the Ethics and Whistleblower reporting page from Gavi’s homepage. Retaliation for reporting either as a victim or witness to an incident is prohibited. Gavi also provides an employee assistance programme, which can provide further resources to victims and witnesses to incidents of SEAH.

10. IFRC and BRC

Following significant and focussed efforts by senior management over the last 5 years to actively engage personnel and those we serve in breaking taboos and building trust around the reporting of sexual misconduct, including investment globally in training and awareness raising as well as accessible complaint mechanisms IFRC has seen a significant increase in reporting. Whilst reports have increased year on year- the number of complaints reached its highest level following IFRC`s implementation of Integrity Line which offers multiple mechanisms for reporting and has been increasingly operationalised by National Societies with the IFRC Network. 2022 was the first full year IFRC used Integrity Line as a reporting mechanism and as anticipated in line with efforts to establish a speak up culture IFRC saw a very significant increase in concerns of all types of misconduct being reported including SEAH.

Up to December 2022, the IFRC Secretariat:

• received 18 new SEA concerns, 17 investigations opened of which 5 related to IFRC personnel and others related to IFRC partners in receipt of IFRC funding
• received 4 concerns regarding Child Safeguarding which are categorised separately within Integrity Line
• received 16 new Sexual Harassment (SH) concerns
• during the year IFRC’s OIAI closed 8 investigations into SEA and 1 SH cases. 5 of these related to IFRC staff whilst the outcome of other investigations were passed onto National Societies for action
• all IFRC personnel against whom substantiated SEA investigations were established were dismissed

The percentage of total allegations of SEA and SH received in 2022 appears lower than those reported in 2021 (4% in 2022 rather than the 9% in 2021 of allegations regarding SEA cases, and 1.72% rather than 3% regarding SH cases). However, numerically there are more cases, 1 SEA case and an increase of 10 on 2021 figures. Cases are notably more complex and concerns regarding Child Safeguarding were raised for the first time which may/not be related to the mandatory inclusion of Child Safeguarding Assessments in IFRC supported work. Investigation rate reporting metrics have changed so that whilst in 2021 multiple allegations might relate to the same investigation IFRC has adopted a more focussed approach in line with industry standards.   

Between September 2022 and September 2023, the BRC received a total of 10 safeguarding concerns. 4 of these were categorised as SEA and 6 as SH. Out of these concerns 4 related to a BRC staff member and 6 related to partners.

• 2 SEA cases of BRC personnel led to an internal investigation:
  • 1 case was substantiated, and the SOC was dismissed
  • 1 case is still active, and the SOC is suspended while a criminal investigation takes place
• 2 SEA cases of partner personnel:
  • 1 did not lead to an investigation and the allegations were dismissed
  • 1 has an investigation ongoing
• 2 SH cases relating to BRC personnel:
  • 1 did not lead to an investigation and allegations were dismissed
  • 1 led to an investigation. Disciplinary action taken
• 4 SH cases relating to partner personnel:
  • 2 cases led to an internal investigation. The concerns were substantiated in 1 case but remain unknown to BRC in the other case
  • 1 case led to initial fact finding where the concerns were substantiated
  • 1 case was reported to the BRC and has been referred to the partner. Partner has taken appropriate action

Although we have had a slight increase in the number of reports, they remain at a low level. This may be attributed to potential underreporting by organisational personnel and implementing partners. In response to this concern, we have devised a plan to enhance the training program for our staff. This initiative will encompass a new e-learning component, complemented by in-person participatory training sessions. We will also be developing safeguarding rules of engagement for partners, to ensure clarity of reporting requirements.

1. Australia, Belgium, Denmark, Finland, Italy, France, Germany, Luxembourg, The Netherlands, New Zealand, Norway, Portugal, Spain, Switzerland, United Kingdom, representing around 85% global ODA in 2021; with other donors subsequently also using very similar language (Canada, Ireland, Japan, USA.) ↩

2. The UN Secretariat, UNDP, UNFPA, UNHCR, UNICEF, UNRWA, UN Women, WFP, FAO, IOM and WHO, with others tbc. ↩

3. Australia, Belgium, Finland, Ireland, the Netherlands, New Zealand, Norway, Switzerland & UK, endorsed by Germany. ↩

4. African Development Bank, Asian Development Bank, Asian Infrastructure Investment Bank, Caribbean Development Bank, European Bank for Reconstruction and Development, European Investment Bank, Inter-American Development Bank, International Fund for Agricultural Development, International Monetary Fund, Islamic Development Bank, World Bank Group. ↩

5. Asian Development Bank (ADB), African Development Bank (AfDB), Asian Infrastructure Investment Bank (AIIB), European Bank for Reconstruction and Development (EBRD), European Investment Bank (EIB), Inter-American Development Bank (IDB), International Fund for Agricultural Development (IFAD), International Monetary Fund (IMF), and the World Bank (WB), including the International Bank for Reconstruction and Development/International Development Association (IBRD/IDA) and the International Finance Corporation (IFC). ↩

6. SEAH is seen as a form of gender-based violence (GBV). Most IFIs refer to the risks around SEAH in their operations under the umbrella of gender-based violence and harassment (GBVH). Thus, the term GBV or GBVH is sometimes used throughout this update report, interchangeably with SEAH. ↩

7. Principle 1: Foster a culture of respect and high standards of ethical behaviour across institutions; Principle 2: Establish and maintain standards aimed at preventing sexual harassment, abuse, and exploitation and other forms of misconduct; Principle 3: Provide a safe and trusted environment for those affected by sexual harassment, abuse and exploitation to step forward to report incidents and concerns, with the assurance that they will be treated respectfully and consistently; Principle 4: Provide protection for those affected, as well as whistle-blowers and/or witnesses within their institutions, and to take appropriate measures against any form of retaliation; Principle 5: Maintain robust policy frameworks and clear institutional mechanisms that address how incidents and allegations will be handled should they arise; Principle 6: Provide effective training programs so all staff understand the requirements and standards of behaviour expected of them as international civil servants and; Principle 7: Support clients to develop and implement policies and mechanisms that address sexual harassment, abuse and exploitation ↩

8. The Department for Science, Innovation and Technology (DSIT), The Foreign Commonwealth and Development Office (FCDO), The Department of Health and Social Care (DHSC), Wellcome, UK Research and Innovation (UKRI). ↩

9. Section 6, Equity and Fairness. ↩

10. Section 7, Equity and Fairness. ↩

11. Nigeria, Zimbabwe, Eswatini, Lesotho, Namibia, Kenya, Sudan, Ukraine. ↩

12. British Red Cross, Netherlands Red Cross, Australian Red Cross, Canadian Red Cross. ↩

13. Australia, Bangladesh, Bahamas, Belarus, Burundi, Cameroon, Core d’Ivoire, Egypt, Eswatini, Fiji, Finland, Kenya, Kyrgyzstan, Lebanon, Lesotho, Liberia, Malawi, Mozambique, Myanmar, Namibia, Niger, Nigeria, North Macedonia, Panama, Poland, Sierre Leone, Solomon Islands, Somalia, South Sudan, Sweden, Syria, Tajikistan, Tanzania, Turkiye, Uganda, UK, Zambia, Zimbabwe. ↩

14. Afghanistan, Botswana, Ethiopia, Gambia, Guatemala, Lao PR, Libya, Lithuania, Malaysia, Mongolia, Nepal, Netherlands, Norway, Palestine, Pakistan, Papua New Guinea, Philippines, Serbia, Sri Lanka, South Africa, Vanuatu. ↩

15. Denmark, Eswatini, Kenya, Mozambique, Tanzania, Argentina, Bahamas, Canada, United States, Australia, Bangladesh, Cambodia, Cook Islands, Fiji, Ireland, Kiribati, Lebanon, Malaysia, Maldives, Mongolia, Myanmar, Nepal, New Zealand, North Macedonia, Papua New Guinea, Philippines, Poland, Solomon Islands, Syrian Arab Republic, Timor Leste, Tonga, Turkiye, Ukraine, UK, Vanuatu, Vietnam. ↩

16. Ecuador, Eswatini, Lao PR, Lesotho, Liberia, Malawi, Nigeria, Pakistan, Sri Lanka, South Sudan, Uganda, Zimbabwe. ↩

17. Including Afghanistan, Bangladesh, Burkina Faso, Chad, Eswatini, Ethiopia, Greece, Iraq, Kenya, Lebanon, Lesotho, Mauritania, Moldova, Myanmar, Namibia, Nepal, Niger, Nigeria, Pakistan, Poland, Romania, Sierra Leone, Somalia, Sudan, Syria, Turkiye, Yemen, Zimbabwe. ↩