Guidance

Child Safeguarding Due Diligence: for external partners

Updated 30 June 2026

FCDO’s approach to enhanced due diligence safeguarding

FCDO has in place standards under the Safeguarding against Sexual Exploitation and Abuse and Sexual Harassment (SEAH) Due Diligence Guidance for FCDO implementing partners that cover partner policies and processes on safeguarding, complaints and whistleblowing, human resources, risk management, codes of conduct and governance. These standards help FCDO to assess an organisation’s ability to mitigate safeguarding risks in their work including to safeguard children and vulnerable adults from sexual exploitation and abuse.

Purpose of this guidance on child safeguarding

This guidance builds on FCDO’s enhanced due diligence safeguarding approach and provides additional framing on child safeguarding for programmes that involve, or may come into contact with, children. It outlines key considerations and indicative questions across the 6 safeguarding policy areas, based on internationally recognised standards such as Keeping Children Safe. The aim is to support organisations in understanding FCDO’s expectations, strengthening their own safeguarding systems, and ensuring appropriate measures are in place to prevent harm to children and respond safely and effectively if concerns arise.

What is child safeguarding?

Child safeguarding refers to the responsibility of organisations to prevent and protect children from all forms of abuse, exploitation, neglect and to promote their safety and wellbeing. For the purposes of all FCDO-supported work and in line with the UN Convention on the Rights of the Child (UNCRC) and the Children Act 1989, a child is defined as anyone under 18 years old, regardless of local laws, age of majority and cultural norms.  

Safeguarding applies to all children, regardless of their age, disability, gender, faith and race. Certain contexts, including humanitarian crises, displacement, conflict, poverty, and social or gender inequality, can heighten a child’s vulnerability and exposure to harm and reduces their ability to access protection or support.

There are emerging risks linked to the use of digital technologies, such as online grooming, live-streamed abuse, AI-generated sexual imagery of children, and exploitation facilitated through different platforms which are rapidly evolving and require specific attention in programme design and partner safeguarding systems.

Preventing harm requires organisations to have robust, proactive safeguarding systems, including safe recruitment and vetting, codes of conduct, behaviour protocols, child-friendly reporting mechanisms, safe participation practices, and survivor-centred child-sensitive response pathways. Meaningful engagement with people with lived experience, should inform the design, monitoring and review of safeguarding measures, ensuring participation is safe, voluntary and age appropriate.

Grounded in a child-rights approach, the UK’s obligations under the UNCRC and the Lanzarote Convention require FCDO and its partners, to respect, protect and fulfil every child’s right to safety and freedom from violence, including preventing abuse, providing child sensitive support to victims and survivors, and ensuring effective accountability for perpetrators.

Child safeguarding in FCDO’s work

Safeguarding children from harm, including sexual exploitation, abuse and harassment, is central to FCDO’s work. In many of the contexts in which FCDO operates, such as conflict, extreme poverty and natural disasters, children may face increased risks of abuse, neglect and exploitation. These harms violate children’s rights and can have severe long term impacts on their wellbeing and development.

FCDO’s primary safeguarding focus is the prevention of sexual exploitation, abuse and harassment (SEAH). But we recognise and act to prevent broader harms including physical abuse, online abuse, emotional harm, neglect and commercial or economic exploitation.

Where programmes involve or may come into contact with children, FCDO expects partners to have appropriate measures in place to prevent harm and to identify and manage child safeguarding risks. This includes maintaining clear behaviour standards, safe and appropriate engagement practices, child-friendly reporting mechanisms, and ensuring staff and volunteers are appropriately trained and vetted.

How this guidance is applied to FCDO programmes

This guidance applies to FCDO supported programmes that involve children either directly or indirectly. This includes programmes where children are the primary beneficiaries (such as education, health, nutrition or social protection) and programmes that may come into contact with children in the course of delivery (for example, infrastructure, economic development, or livelihood activities).

Some contexts present heightened safeguarding risks for children, particularly where unequal power dynamics, discrimination, or harmful social norms influence interactions between adults and children. Children without adequate adult protection, including those without parental care or children with disabilities, may face additional vulnerability. Organisations should consider these risks holistically, including through the lens of gender, disability and other characteristics that may increase the likelihood of harm.

FCDO takes a risk-based and proportionate approach to safeguarding requirements. Where programmes involve direct engagement with children or take place in higher risk contexts, organisations may be asked to demonstrate stronger child safeguarding measures and provide evidence across the relevant areas of FCDO’s wider SEAH due diligence framework. The level of evidence required will depend on the nature of the programme and the risks identified.

Child safeguarding across the due diligence pillars

Below are the areas that FCDO teams will cover when assessing an organisation’s child safeguarding arrangements as part of the overall enhanced SEAH due diligence. These questions are applied where an organisation’s work directly or indirectly involves children, or where there is a reasonable expectation that staff, partners or activities could come into contact with children.

Focus area	Indicative questions we may explore
Safeguarding approach	Does your organisation have a child safeguarding policy that applies to all staff, volunteers, contractors and associates? Does the policy recognise that some children face heightened risks (for example, due to gender, disability, ethnicity or other factors)? Is the policy accessible to children and caregivers in age‑appropriate and inclusive formats? Are safeguarding risks associated with staff conduct, programming and online activities clearly addressed? Are there systems in place to implement the policy (for example, training, reporting pathways, focal points)?
Complaints and whistleblowing	Are there clear reporting mechanisms for staff, volunteers, children and caregivers to raise concerns safely? Are reporting options child‑friendly and disability‑inclusive? Is it possible to report concerns anonymously? Are staff trained to receive disclosures from children in a safe and sensitive manner? Are there procedures for responding to allegations of child abuse or exploitation, including referral to specialised services?
Recruitment and training	Are safeguarding responsibilities reflected in job descriptions, adverts and contracts? Do recruitment processes include appropriate vetting and reference checks? Are safeguarding focal points designated at different organisational levels? Do staff and volunteers receive training on child safeguarding, risk factors and barriers to reporting?
Risk management	Are child safeguarding risks identified and assessed for relevant programmes and activities? Are mitigation measures included in programme design, delivery, monitoring and evaluation? Does the organisation have tools such as risk assessments, case management guidance or risk‑management procedures?
Code of conduct	Does your organisation have a code of conduct outlining appropriate and prohibited behaviour with children? Is the code mandatory for all staff and associates? Are expectations for conduct during events, community engagement and online activities clearly specified?
Governance and accountability	Does senior leadership understand where the organisation engages with children and the associated safeguarding risks? Is there a system for safeguarding performance, incidents or concerns to be reported to the governing body or board? Are children and caregivers meaningfully involved in designing or reviewing safeguarding measures? Are feedback mechanisms accessible, child‑friendly and disability‑inclusive?

Interviews or consultations involving children, including child-survivors, should only be conducted by trained child protection specialists to ensure children’s safety and to prevent re-traumatisation. If partners have concerns about safeguarding-related issues within programmes, these should be raised through their organisation’s safeguarding procedures and, where appropriate, through the FCDO Reporting Concerns (reportingconcerns@fcdo.gov.uk) process.

Child safeguarding responsibilities for the FCDO and partners

In the UK, it is illegal for anyone in a position of trust to engage in sexual activity with a child under 18 in their care (Sexual Offences Act 2003). The Act also enables the UK to prosecute UK nationals for child sexual offences committed overseas, including where the behaviour may not be a crime in the country where it occurred. FCDO expects all staff, partners, and any individuals involved in the delivery of UK aid to understand and comply with this legislation.

FCDO has a zero-tolerance approach to all forms of abuse, exploitation, neglect, bullying or harassment of children. We expect partners to uphold the same high standards and to create safe environments for children in all activities connected to UK-funded work. All staff and partners must remain alert to child safeguarding risks during programme delivery, engagement with communities, site visits, spot checks, and when visiting schools, colleges or any settings where children are present. Safeguarding expectations set out in due diligence should be actively monitored and followed in practice.

If any concerns or allegations of abuse, exploitation or harm involving children arise, partners are expected to take immediate action in line with their own safeguarding procedures, including reporting, responding and ensuring appropriate support.

Information management and communications with children

Organisations must carefully consider how information about children is collected, stored and used, including in digital communications and outreach. Poorly managed communications can expose children to risks such as online grooming, stigmatisation, retaliation, violence or bullying, particularly if their identity, location or circumstances are revealed.

Parental or caregiver consent must be obtained before using images or stories of children. Even with consent, organisations must assess the potential impact on the child and ensure that communications do not place them at risk.

Minimum safeguarding expectations include:

• ensure images and stories uphold children’s dignity and never show them in undignified, undressed or inappropriate situations
• avoid sharing images or information that could identify or endanger children, particularly those in high‑risk situations (for example, conflict‑affected settings or cases involving exploitation or violence)
• ensure captions and background details do not reveal personal information or specific locations; geotagging must be disabled
• assess the risk of identifiable visual cues (for example, uniforms, disability aids, recognisable buildings) before publishing and avoid material that could create or increase risk
• ensure all staff, photographers and journalists involved are appropriately vetted
• obtain informed permission from children and caregivers, ensuring they understand how the material will be used and where it may appear
• limit the amount of personal information shared and assess how content could be reused, repurposed or misused

Safeguarding children’s online participation

This guidance provides a concise overview of the essential safeguards FCDO expects partners to apply when involving children in online activities. It is intended as a practical baseline and should be used alongside each organisation’s existing safeguarding policies and other sector guidance.

Online engagement can offer meaningful opportunities for children to participate in events, consultations, and research. It can also introduce specific risks. FCDO expects all partners to ensure that online participation is safe, respectful, voluntary, and protective of children’s wellbeing.

Before the activity

• obtain informed consent from children and parents/guardians, including clear information about purpose, risks, how data will be used, and the right to withdraw
• provide basic online safety information to children and guardians. Personal data that identifies a child must not be shared
• conduct a safeguarding risk assessment and ensure safe access arrangements (for example, invite‑only events, secure links, waiting room functions)
• ensure children have a pre‑meeting or briefing to understand the platform and feel comfortable

During the activity:

• use child‑appropriate communication and content. Moderators should facilitate questions and manage participation
• if online, maintain secure digital settings: password‑protected access, monitored participant list, and controlled screen‑sharing
• ensure safeguarding oversight during the session and follow your organisation’s procedures if a concern arises

After the activity:

• provide follow‑up opportunities for children to share feedback
• inform children how their contributions will be used and share outcomes where appropriate

Reporting concerns on child safeguarding to the FCDO

All child safeguarding concerns relating to our staff or programmes should be reported promptly to the FCDO Safeguarding Investigations Team by email reportingconcerns@fcdo.gov.uk or through the confidential reporting hot line +44 (0)1355 843 747.

FCDO Safeguarding Investigations Team refer suspected cases of child sexual exploitation and child sexual abuse by UK nationals or individuals with a claim to UK residency to the National Crime Agency where the offences are alleged to have occurred abroad. When safe and appropriate to do so (for example, in the best interests of the child), FCDO Safeguarding Investigations Team will also ensure such referrals are made to other national jurisdictions.

FCDO Safeguarding Investigations Team have trained staff who will provide an age appropriate response or service if a child or young person contacts reporting concerns, either via email or through calling the reporting line. If there is a child survivor or witness, any interviews will be undertaken by specially trained professionals.

Support during the due diligence process

In line with all other FCDO due diligence processes, this assessment will be carried out collaboratively as much as is possible, with each organisation. Prospective partners will have opportunities throughout the process to discuss any areas they are unsure about and to request clarification where needed. Once completed, a draft assessment will be shared with the partner for review and comment.

If organisations are compliant with the IASC MoS-PSEA and/or the SEAH elements of the CHS then they should be in a position to demonstrate effective policies for managing and addressing the risk of SEAH. The Humanitarian Quality Assurance Initiative (HQAI) provides independent verification of organisations’ compliance with the CHS. The CHS Audit reports offer rich information on a partner’s controls and processes and will reduce the number of details needed to be gathered in the Due Diligence process.