Corporate report

Foreign, Commonwealth and Development Office progress report on safeguarding against sexual exploitation, abuse and harassment (SEAH) in the international aid sector 2022 to 2023

Published 30 January 2024

A summary of work led or supported by the Foreign, Commonwealth and Development Office (FCDO) between August 2022 and October 2023 to improve global standards and performance on safeguarding against SEAH in the international aid sector, as well as highlights of work in the 5 years since October 2018.

Putting people first: tackling sexual exploitation, abuse and harassment in the aid sector.

1. Executive summary

This report is the fifth annual progress report since 2018. This year’s report is different to the previous reports in that it looks back at the 5-year period as a whole, as well as updating on developments in the most recent annual reporting period. It contains an Executive Summary, Significant Highlights and detailed sections on each of the Strategic Shifts, which framed the 2018 commitments.  It also has a section on Challenges, Scrutiny and Next Steps.

• since 2018, the UK has played a leading role in pushing for improved global standards on safeguarding against sexual exploitation and abuse and sexual harassment (SEAH) in the international aid sector

• at the October 2018 London Safeguarding Summit the UK, alongside other donors and a range of other international partners, made commitments to bring about 4 strategic shifts to prevent and better respond to SEAH in the aid sector (see Annex B). The full list of additional partners and progress reporting is available on GOV.UK

• 5 years on, these commitments continue to guide FCDO’s work on SEAH and also the approach of the UK Government as described in the 2020 UK safeguarding strategy progress against which is covered in Annex A. The Government’s May 2022 International Development Strategy (PDF, 1.1 MB), March 2023 Women and Girls Strategy and November 2023 International Development White Paper reaffirmed our determination to drive progress internationally on safeguarding work and to improve standards, identify perpetrators and support survivors and victims of SEAH

• this report updates on progress that the UK and FCDO in particular has made during the 5-year period from October 2018 to October 2023 against the 22 donor commitments made at the 2018 Summit. It also highlights the challenges faced. Conflicts and natural disasters around the world increased the risks of SEAH, as did the Covid-19 pandemic. FCDO proactively worked with partners to prevent and respond to harm from SEAH connected with these crises and in our development work. Despite the pressures on the UK’s ODA budget, funding for core FCDO work on SEAH was protected and the UK remained a major contributor to global, national, and local safeguarding initiatives

• FCDO’s work on safeguarding remains subject to regular scrutiny, for example by the UK Parliament’s International Development Select Committee and the Independent Commission for Aid Impact (ICAI). In 2023 the FCDO ran a survey for its staff on SEAH in the workplace and work-related settings. In response to the survey, the FCDO’s Executive Committee agreed a robust action plan. We welcome these opportunities for accountability and transparency, and for learning and making improvements.  This report underlines our commitment to transparency and accountability

2. Highlights

Publication of the UK Safeguarding Strategy

All UK Government Departments who spend Official Development Assistance (ODA) signed up to the 2018 donor commitments. Each department is responsible for its own ODA spend and translating these commitments into action. All UK ODA-spending departments agreed a UK safeguarding strategy on tackling in SEAH in the international aid sector which was published in September 2020. Annex A summarises progress from the past 12 months across all UK ODA-spending departments in implementing the 2020 UK safeguarding strategy.

Global leadership in SEAH safeguarding

In July 2019, the Development Assistance Committee (DAC) Recommendation on Ending Sexual Exploitation, Abuse and Harassment in Development Co-operation and Humanitarian Assistance was adopted. Building on the outcomes of the 2018 London Summit the Recommendation provides a coherent framework for aid agencies and their implementing partners to prevent SEAH and respond better when it occurs. The recommendation was developed by a small team co-chaired by the UK (FCDO), Ireland and Austria and working with the DAC Secretariat. It has been adopted by all DAC members whose performance against it is monitored through the DAC peer review mechanism. The UK continues to help lead engagement across the DAC, as co-chair, with the Unite States and Canada, of the DAC Reference Group on SEAH.

The UK helped develop the 2018 G7 Whistler Declaration on protection from sexual exploitation and abuse in international assistance. During the 2021 UK Presidency, G7 countries reaffirmed their commitment to tackling SEAH, and did so again during the Japanese 2023 Presidency.

Driving change and accountability in multilaterals

UK Prime Ministers have joined the UN Secretary General’s Circle of Leadership on the prevention of and response to sexual exploitation and abuse in United Nations operations. Alongside other Member States, the UK has used its position on boards of multilateral organisations to encourage continued focus on tackling SEAH and drive progress. In December 2021 the UK and 26 other Member States and the EU jointly wrote to the UN Secretary-General setting out asks of the UN system in tackling SEAH and proposing a Strategic Dialogue to further explore challenges and actions required to accelerate progress. This initiative was welcomed by the UN and resulted in a meeting hosted by the Special Coordinator for Preventing Sexual Exploitation and Abuse in May 2022. The UK and 64 other Member States delivered a joint statement at the session.

We continue to ensure that FCDO’s funding agreement documents are explicit that we expect partners to align with international standards to protect against SEAH, and work with other donors to maximise consistency in our expectations and asks, for example, by using harmonised SEAH language agreed with 14 other donors and with the UN, and beginning a dialogue with the International Financial Institutions (IFIs) to agree a similar approach. When considering providing programme funding to multilaterals and other partners we assess their commitment, capability and processes related to Protection against SEAH as a core pillar of our due diligence process. Recommendations from the assessment and progress against them are tracked through regular programme reviews.

Data and transparency

The trend on reporting of cases during the 5-year period, both internal and external cases, has been a general increase. There was a fall in external cases reported in 2021 to 2022, and internal cases from 2020 to 2021 – which may have been due in part to Covid and higher numbers of staff working from home. The overall increase in reporting since 2018 suggests rising staff confidence that when concerns are reported that they will be addressed and that disciplinary action, up to and including dismissal, is being taken when justified. FCDO has done a lot of work internally to raise awareness of SEAH and to encourage staff to report when incidents occur.

Catalysing change through programmes

Safeguarding Innovation and Engagement Programme

• the Safeguarding Innovation and Engagement Programme was established in 2018 to drive change across the international aid sector through funding innovative pilot projects to test new approaches to PSEAH working with a range of partners, including multilaterals, CSOs and the private sector. This flexible approach has continued in the last year. The programme is due to end in mid-2024 and a successor programme is being designed

The Resource and Support Hub

• the online Safeguarding Resource and Support Hub was established following the 2018 Summit to support organisations in the aid sector to strengthen their safeguarding policy and practice against SEAH. It has expanded to new regions over the past 5 years supporting hundreds of thousands of individuals in hundreds of local and international organisations

Support to victims and survivors

• strengthened support to survivors, including through funding to the Office of the Victims Rights Advocate, the UN Trust Fund, and more recently a pilot programme in Malawi.  A key milestone was the publication of the UN statement of victims’ rights in 2023 (PDF, 1.5 MB) whose development we supported

Project Soteria

• work funded by the FCDO is also making it harder for perpetrators of SEAH to work in international development. Project Soteria with Interpol has strengthened cooperation between law enforcement agencies and aid organisations globally. The Misconduct Disclosure Scheme, funded by FCDO under a related programme, has led to 230 new hires being rejected in total since 2019

Improving our own capacity, capability and confidence

FCDO has invested significant resources to ensure staff are aware of their responsibilities when it comes to SEAH and managing related risks in their work. For example, FCDO has mandatory training for all staff, runs regular more detailed training and has developed resources such as case management guidance and FAQs. In 2023 the FCDO ran a survey for its staff on SEAH in the workplace and work-related settings. Over 3,400 FCDO staff from around the world responded. The main findings were that 23% of women and 6% of men reported having experienced SEAH over the past 12 months related to their work, underlining the need for continued focus on tackling SEAH to help protect our own staff as well as others we work with directly and indirectly.

Looking ahead

Despite progress in the last 5 years, challenges of fragmentation and the lack of sustainable funding and management approach across the international system remain. We remain committed to making progress and driving momentum. An important milestone is the launch, in November 2023, of the online public consultation of the Common Approach to Protection from SEAH (CAPSEAH) which 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 better aligning approaches to SEAH across countries, organisations and programmes.

The draft CAPSEAH marks a significant step forward. It was developed by an international Steering Committee and wider consultation. FCDO is providing the secretariat for the committee as part of our contribution to help drive accelerated progress on safeguarding against SEAH.

3. Strategic shift 1: Ensure support for survivors, victims and whistle-blowers; enhance accountability and transparency; strengthen reporting; and tackle impunity

FCDO remains firmly committed to taking a survivor-centred approach. This means putting the victims’ or survivors’ rights, needs, safety, dignity, wellbeing and wishes at the centre of our thinking, based on principles of safety, confidentiality, respect and non-discrimination. We will keep working to ensure any victim-survivor feels able to speak up and to challenge abuses of power underpinning SEAH.

Progress highlights

FCDO’s Programme Operating Framework continues to guide our safeguarding programme spend. This and other internal guidance makes it clear that beneficiary engagement, particularly at the design stage, is an important component of programme work, including to ensure that beneficiaries are safe from harm and empowered to speak out wherever harm does occur (commitment 1). ^{[footnote 1]} FCDO continued funding the harmonised SEAH data collection and reporting project through the Core Humanitarian Standard (CHS) Alliance and the Steering Committee for Humanitarian Response. The harmonised data project aims to increase transparency on SEAH and reduce under-reporting by introducing a harmonised SEAH data collection and reporting framework. It provides comparable SEAH data that can facilitate trend analyses, enhance understanding of the issues and inform policies, strategies and interventions and so help improve prevention and the support provided to victims and survivors (commitment 2). A Steering Committee was created in June 2022 with representatives from NGOs, donors (FCDO and USAID), the private sector and the UN. So far 25 organizations have joined the scheme including 11 International Non-Governmental Organisations (INGOs), 8 National Non-Governmental Organisations (NNGOs), 1 Red cross society and 4 private sector organisations. A draft framework was successfully piloted over 12 months resulting in key findings (PDF, 3.3 MB) that will inform the scale-up of the programme from January 2024. Donors and their implementing partners are strongly encouraged to take part in the scheme.

FCDO continued to support employment cycle initiatives (commitment 3). Project Soteria aims to prevent perpetrators of SEAH from working in the aid sector by strengthening cooperation between law enforcement agencies and aid organisations. It is being piloted in 6 countries: Bangladesh, Nepal, Philippines, Uganda, Tanzania and Kenya, with related work in support of countries responding to the conflict in Ukraine. Since 2019 the FCDO-supported Misconduct Disclosure Scheme (MDS) has been used to facilitate the sharing of misconduct data between employers. To date, over 86,000 checks have been conducted in 60,198 recruitments and this has helped to prevent the filling of 230 posts where there was missing or negative misconduct information. The scheme is currently being implemented by over 220 organisations from diverse backgrounds. The annual data figures from the MDS show that the scheme has grown significantly since it began in 2019 with the number of requests for misconduct data having increased from 2,681 in 2019 to 57,065 in 2022.

In July 2023 FCDO again published data about the number of external and internal cases (Commitment 4). Internal cases are classed as those where either the survivor and/or the subject of complaint are FCDO employees. For internal cases we have also seen a year-on-year increase from 2017 to 2018 to 2023, apart from 2020 to 2021. We believe the drop in internal cases during 2020 to 2021 was in part due to COVID and most staff working from home throughout the year. FCDO has been doing extensive work internally to raise awareness of SEAH and to encourage staff to report when incidents do occur. Mandatory training is in place for all staff, guidance and resources have been developed, and regular messaging from senior leaders on FCDO’s zero-tolerance to inaction approach to SEAH. The increase in reporting suggests rising staff confidence that when concerns are reported that they will be looked into and that disciplinary action, up to and including dismissal, is taken when allegations are upheld.

As part of ongoing capability work we run regular case management training for programme teams. We have also developed resources such as case management guidance and Frequently Asked Questions.

We currently chair the Donors’ Safeguarding Investigations Group (DOSIG), established by FCDO at the end of 2020 with the aim of providing a forum for like-minded donor governments to discuss best practice and share common challenges in the area of SEAH investigations. The group has grown this year to twelve members, with Ireland and Norway joining in 2022 to 2023. Since it was established, the group has met regularly and the FCDO took part in a 2 day in-person workshop hosted by the Netherlands in April 2023. Areas of focus for the group have included specialist SEAH investigations training, the survivor-centred approach, rights of subjects of investigations, information sharing challenges and reporting expectations.

FCDO continues to implement its programme to support victims and survivors launched in 2021. We have been the largest donor to the UN Trust Fund to support victims of SEA and fund the Office of the Victims’ Rights Advocate (OVRA).  OVRA’s Victims’ Rights Statement (PDF, 1.5 MB) was endorsed by the Secretary-General’s High-Level Steering Group (HLSG) on Sexual Exploitation and Abuse in 2023, setting out 10 rights of all victims of SEA committed by UN or related personnel.  We have funded Social Development Direct to build the capacity of women’s rights organisations in Malawi to receive and respond to SEAH cases.  We also funded an independent charity Loop to develop and pilot a digital platform to safely receive and appropriately handle reports of SEAH. We continue to convene an Independent Reference Group which includes survivors of SEAH and survivor representatives to act as a sounding board for our work and we have engaged with groups representing survivors and victims (commitment 5).

The review of lessons from ombudsman schemes was completed in 2018, concluding that there was little support to create an independent ombuds system for the aid sector. We and other donors have though continued to support initiatives to improve aid sector accountability. FCDO supported and financed the development of a 4-tiered Investigator Qualification Training Scheme, with the CHS Alliance, to strengthen standards of SEAH investigations. Module 1 is free of charge and available on the Disaster Ready website. Information on training dates and costs for Modules 2 and 3 is available on the Alliance’s website, alongside general information, the course Investigation Guide (PDF, 1.1 MB) and a useful FAQ (PDF, 150 KB)

FCDO also worked with the CHS Alliance to develop and publish guidance on whistle-blower protections (PDF, 3.6 MB) and is part of a Steering Committee for a project designed to close the accountability gap for survivors of SEAH (commitment 6).

4. Strategic shift 2: Incentivise cultural change through strong leadership, organisational accountability and better human resource processes

The causes of SEAH are rooted in power imbalances, including inequality and discrimination relating to gender, disability, sexual orientation, poverty, race and ethnicity, among other factors. We must tackle underlying inequalities within our organisations and the communities in which we work. At FCDO, this starts with setting the tone from the top and ensuring staff understand that safeguarding is everyone’s responsibility.

Progress highlights

FCDO continues to have a nominated Safeguarding Sponsor on its Executive Committee (commitment 7).  Progress on safeguarding is regularly tracked and discussed through both a Safeguarding Delivery Board and the Management Board (commitment 8). The past 5 years have resulted in, among other things: new FCDO accountabilities tables, which clearly outline what is expected of staff in leadership positions when it comes to safeguarding against SEAH; setting up FCDO’s Tackling Sexual Harassment Implementation Group; developing a robust Safeguarding Policy; as well as frequent messaging from senior management on the FCDO’s zero tolerance to inaction on SEAH.  Safeguarding remains one of FCDO’s risk categories and embedded into FCDO’s risk approach and Programme Operating Framework (commitment 16). Organisational safeguarding risk continues to be reviewed regularly by FCDO’s Management Board.

In 2023 the FCDO ran a survey for its staff on SEAH in the workplace and work-related settings. The survey was modelled on the 2020 Gender and Equalities Office sexual harassment survey. Over 3,400 FCDO staff from around the world responded. The main findings were that 23% of women and 6% of men reported having experienced SEAH over the past 12 months related to their work. While below the UK average for workplace reporting, the levels are completely unacceptable. Sexual comments, jokes and unwanted staring were the most common experiences. Perpetrators were colleagues or external work contacts.

In response to the survey, the FCDO’s Executive Committee agreed a robust action plan.  Actions in 2024 will include: an internal campaign led by male staff to make clear that sexual comments and other forms of SEAH are wholly unacceptable; training for line managers on how to respond to reports of SEAH and for bystanders who witness acts of SEAH; further support to build the safeguarding capability of external partners; and continued work to make it easier to take action against perpetrators. Towards the end of 2024, FCDO’s Management Board will assess progress and agree priority actions for 2025.

Other steps taken to promote equality and inclusion in FCDO (commitments 9 and 10) include: implementation of the FCDO Inclusion Framework and Civil Service Diversity and Inclusion Strategy 2022 to 2025; provision of gender pay gap statistics; continued implementation of initiatives to encourage women to be in more senior leadership roles; and being a signatory to the Business in the Community (BITC) Race at Work Charter including having a Board sponsor for race.

FCDO continues to encourage leadership, organisational change and accountability on PSEAH across all our partnerships, including the UN and International Financial Institutions (commitments 7 to 13). We encourage improvements through our programme funding to multilaterals and other partners - assessing our partners’ PSEAH commitment, capability and processes as a core pillar of our due diligence process and using these assessments to have an in depth discussion on progress and challenges. Recommendations and progress are tracked through annual programme reviews. We also work closely with other governments to maintain a strong focus on zero tolerance to inaction on SEAH and drive improvements through: participation and joint statements in multilateral boards and at the May 2022 Strategic Dialogue with the UN on SEAH; UN resolutions; and international fora such as the DAC SEAH Reference Group and MOPAN (PDF, 114 KB) (the Multilateral Organisation Performance Network Association - commitment 13). Over the last year we have been providing the secretariat for an international Steering Committee and wide consultative network involving organisations including the UN, IFIs, civil society organisations and women’s rights groups, the private sector and governments to develop a Common Approach to Protection from SEAH (CAPSEAH) to drive alignment of effort, strengthen accountability and prevention of SEAH cases, and improve support to victim-survivors.

FCDO supported a full-time coordinator to lead the United Nations Chief Executive’s Board for Coordination (CEB) Sexual Harassment Taskforce. The Taskforce is comprised of senior managers from UN system organisations and reports to the High-level Committee on Management (HLCM). It is a UN system-wide project to harmonise and strengthen policies, outreach, accountability, investigations, and victim support, to prevent and respond to sexual harassment across the UN system. FCDO also funded The Sexual Exploitation and Abuse Risk Overview Index (SEARO) project, in collaboration with relevant parts of the UN on behalf of the Inter-Agency Standing Committee (IASC). The SEARO is a composite index that brings together information on a range of factors known to influence the risk of sexual exploitation and abuse perpetrated by aid workers in humanitarian contexts. The project supported greater understanding of SEA risks and analysis, decision-making and resource allocation for SEA at global and country levels. The SEARO index is being used at strategic system-wide level, and by different humanitarian actors.

5. Strategic shift 3: Adopt minimum standards and ensure we and our partners meet them

FCDO works with organisations across the aid sector, including other donors, the UN, non-governmental organisations (NGOs), private sector and others, to align approaches, share lessons, and incentivise our partners to adhere to internationally agreed minimum standards on SEAH.^{[footnote 2]}

Progress highlights

The 2020 UK Safeguarding strategy requires all organisations receiving UK ODA to take robust safeguarding measures. FCDO chairs a group for all signatories on a quarterly basis to support the implementation of the Strategy. FCDO is itself committed to meeting international standards (commitment 14) as reflected in our staff code of conduct and other documents.

FCDO continues to fund HQAI (the Humanitarian Quality Assurance Initiative) the body that certifies organisations adhering to the Core Humanitarian Standard, including via a Facilitation Fund that supports smaller organisations to access HQAI services. FCDO also maintains close engagement with the CHS Alliance to support the continued embedding of SEAH in the current revision of the standard, building on earlier work that supported the inclusion of harassment for the first time in updating the PSEAH index and handbook, followed by the development of new CHS e-learning on Understanding and Using the CHS PSEAH (Protection from SEAH) Index. The CHS requirements are designed to improve the quality and accountability of aid including to better prevent and respond to SEAH. The PSEAH Index is relevant to all aid sector members and eLearning is free of charge.

We continue to ensure that FCDO’s funding agreements are explicit on requirements for partners to also meet these standards. We work with other donors to maximise consistency in our expectations and asks of partners, for example, by using since 2021 the UN harmonised SEAH language agreed with 14 other donors. In 2023 we and other donors began a dialogue with 13 International Financial Institutions (eg World Bank) to agree a similar approach. FCDO continues to ensure that we assess our partners’ commitment and capacity to tackle SEAH as a core pillar of our due diligence process, and have strengthened guidance on this process for partners and staff, along with internal guidance on child safeguarding (commitment 15). Our due diligence aligns closely with the CHS, the IASC standards and principles and the pillars of the 2019 OECD DAC Recommendation.

The UK is committed to championing the 2019 Development Assistance Committee’s (DAC) recommendation on ending SEAH (commitment 17). We continue to co-chair of the DAC SEAH Reference Group, currently alongside Global Affairs Canada and USAID. We are committed to continued engagement in the DAC and other international fora to build knowledge, commitment and coherence around the DAC Recommendation. We have supported development of a new DAC SEAH toolkit and look forward to taking stock of progress when the results of the 5-year monitoring survey are published in 2024.

6. Strategic shift 4: Strengthen organisational capacity and capability across the international aid sector, including building the capability of implementing partners to meet the minimum standards

Safeguarding remains a priority for FCDO. We want to raise safeguarding capability across the sector to ensure that our partners take all reasonable steps to tackle SEAH. We continue to improve our own policies and procedures and will facilitate the sharing of lessons and guidance with others, including via the Resource and Support Hub which we fund.

Progress highlights

Over the past 5 years we have devised and put into action a plan to boost staff capability (commitments 18 and 20). This has included: extending and updating mandatory training for all FCDO staff; delivering specific sessions for senior leaders to help drive cultural change and reinforce FCDO safeguarding standards wherever staff work; the creation and expansion of a Safeguarding Champions Network; launching an intermediate training package primarily aimed at advisory cadres in line with FCDO’s Shared Advisory Capability Statement (SACS) on SEAH and designed to upskill technical advisers and programme managers to meet the competencies described in the SACS; delivering training to help policy and programme staff manage safeguarding risk; providing sessions to raise awareness and knowledge for all staff through a regular quarterly learning offer as well as annual safeguarding weeks; developing an internal safeguarding against SEAH toolkit for all staff; delivery of training sessions for country-based staff in local languages; and providing targeted support to higher priority in-country teams.

We have invested significant staff time and programme resources to improve the capability of our delivery partners such as local- level NGOs. This includes the Safeguarding Resource and Support Hub (RSH) (commitment 19) which provides free guidance, tools and analysis for all organisations. Since its creation in 2019, RSH has included a global hub operational in English, French, Arabic, Urdu, Bangla and Swahili, and established national hubs in 8 countries across Africa, the Middle East and North Africa (MENA) and South Asia with materials available in other local languages. These hubs provide direct support to CSOs through contextualised resources, training, mentorship and an ‘Ask An Expert’ service which has supported organisations to build a cohort of individuals with safeguarding expertise in different countries.

Since 2019 RSH has successfully developed and tested initiatives to improve safeguarding practices amongst small CSOs in the aid sector, increasing in impact year on year. RSH has reached over 641,000 individuals via its online platform since launch and successfully mentored over 135 CSOs across Africa and MENA. RSH has continued to widen the mentorship programme, which in 2023 also launched in the South Asia hub to support 20 CSOs.

RSH continues to build strategic partnerships to improve and support the implementation of SEAH safeguarding practices. RSH continues to publish new resources, facilitate dialogue and learning between organisations, and conduct research. RSH has a continued commitment to inclusion through collaboration with networks of less-resourced CSOs, working with people with disabilities and to increase engagement with more rural organisations.

FCDO has also provided financing to the UN Refugee Agency (UNHCR) and the International Council of Voluntary Agencies’ (ICVA) Protection from SEA Outreach and Communications Fund, which helps NGOs to create communication materials to raise awareness of safeguarding.   Alongside funding national and community level projects, the fund also uploads materials to a public PSEA deliverables database (PDF, 676 KB) which has over 45 communication products on SEAH awareness and prevention in over forty languages for the sector to use for free and adapt.

Other global initiatives funded by FCDO in the past 5 years include Advanced Safeguarding Leadership Training run by the Open University. After running all 3 modules successfully on FutureLearn where over 4,500 learners enrolled, the course was made available free on OpenLearn Create ensuring it is still accessible and reaching as many people as possible. The training course has now been translated into multiple other languages with funding from the World Health Organisation (WHO).

FCDO has funded British Expertise International to enhance capability building among UK private sector organisations. FCDO staff spoke at multiple learning events involving thousands of participants across a wide range of sectors to share learning, best practice and challenges for the private sector. The Safeguarding Leads Network, as a group representing the private sector in the UK, have also been actively engaged in work to develop a Common Approach to PSEAH.

In terms of commitments 21 and 22 (which focus on maintaining momentum) FCDO continued to engage extensively with external partners. In addition to our work through the OECD DAC Ending SEAH Reference Group, we continued to chair quarterly meetings of the Cross-Sector Safeguarding Steering Group (all groups who made commitments at or related to the 2018 London Summit) and coordinated their latest annual report. We also continued to chair the quarterly donor Safeguarding Technical Working Group (all donors who made commitments at the 2018 Summit) which saw valuable discussions and joint actions on strengthening operational policy and practice.

An important milestone was the launch in 2023 of the global consultation on the Common Approach on Protection from SEAH (CAPSEAH – formerly known as ‘the Global Framework’). The Common Approach will be an online resource which 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 across countries, organisations and programmes.

7. Challenges, scrutiny, lessons and next steps

Challenges

Despite the positive safeguarding journeys of many in the aid sector in the last 5 years, far too many SEAH cases still occur and significant systemic challenges remain which require long-term focus from all involved in humanitarian, development and peacekeeping work.

Data

The lack of data available on cases of SEAH remains a challenge that many organisations face, including the FCDO. Underreporting by survivors and the reluctance of organisations to share and publish information on the number and types of allegations received makes it difficult to fully grasp the scale of SEAH and to analyse long-term trends for comprehensive analysis. Publishing data on SEAH cases in the CSSG annual reports since 2021 is an example of efforts to improve transparency across the sector. The Data Harmonisation Project (PDF, 3.3 MB), funded by FCDO, aims to improve data collection and so policy coherence.  

COVID-19

Since March 2020, the COVID-19 pandemic has posed challenges for the aid sector, delaying some safeguarding initiatives and forcing organisations to rapidly adapt. Fortunately, direct challenges from the pandemic have now reduced and the sector has adapted. Evidence shows that the risk of SEAH increases during emergencies. At the same time, restrictions on movement made it harder to report concerns, engage with beneficiaries and communities, investigate cases, and provide support to victims and survivors.

FCO-DFID merger

The merger in 2020 of 2 large UK Government Departments, bringing together the Foreign and Commonwealth Office (FCO) and the Department for International Development (DFID) to create the Foreign, Commonwealth and Development Office (FCDO) has presented both challenges and opportunities. The challenges have mainly been linked to bringing together different operating systems.  The opportunities have included being able to build capability on PSEAH across more staff and to bring together more closely diplomacy and development channels to continue to champion work to prevent SEAH and improve the response.  

ODA budget pressures

Pressures on the UK’s ODA budget from 2020, as a result of COVID-19 and related reductions in ODA spending, made it more challenging for the FCDO to maintain support to partners on safeguarding against SEAH. Funding for core FCDO work on protection from SEAH has though been largely protected. The UK remains a proactive donor when it comes to thought leadership and funding to SEAH projects that contribute to international, regional and local safeguarding approaches.

Conflicts and natural disasters

Conflicts and natural disasters around the world, such as that linked to Russia’s invasion of Ukraine and escalating Middle East tensions in Israel-Gaza, have also created challenges in the last 5 years by increasing the risks of SEAH. FCDO has proactively worked with partners to drive an effective approach to SEAH risk management in the humanitarian response in Ukraine and the wider region. We supported the launch of the Safeguarding Resource and Support Hub for Eastern Europe to provide specialist support for a set period of time and advice to CSOs working in the region. We funded the translation of SEAH training materials into Ukrainian, Polish, Slovak and Hungarian. We also funded a tool run by Loop to make it easier for communities to report SEAH concerns and have supported gender-based violence programming, which includes the provision of services for survivors of SEAH. Resources previously developed by the RSH MENA Hub are being used by organisations involved in responding to events in Israel-Gaza and FCDO has coordinated with the UN about the PSEAH elements of the UN’s work in Gaza.

Scrutiny

In the last 5 years there has been a high level of scrutiny of our work. The UK Parliament’s International Development Committee (IDC) published a report following their 2018 inquiry into SEA in the aid sector and a subsequent follow-up report in Oct 2019. A third IDC inquiry into ‘SEA in the aid sector – next steps’ concluded in January 2021 and the UK government’s response was published by the IDC in April 2021. The Independent Commission for Aid Impact (ICAI) conducted a review in 2021 to 2022 on FCDO’s safeguarding work in the humanitarian sector. This has been welcome scrutiny, which has offered the FCDO valuable feedback and opportunities to reflect on its approach to PSEAH and consider where our work can be strengthened.

Lessons and next steps

The main lesson learnt from the past 5 years of focused effort is that tackling SEAH is something that we must hard-wire into FCDO’s everyday work and that of all organisations we work with. Sustained effort is required on multiple fronts: to drive cultural change internally and externally to make it much less likely that SEAH occurs; to give survivors/victims and others the confidence to report what they experience, witness or hear about; to make it easier to identify perpetrators and to persuade them that they can’t get away with what they do; and to improve the support provided to survivors and victims and ensure that their needs and wishes are prioritised rather than organisations’ reputations.    

Looking ahead, we will continue to implement the UK Safeguarding Strategy and to convene stakeholder groups across the sector to ensure momentum on PSEAH is maintained and that there are strong networks to draw on and influence. We will continue to work on the Common Approach to Protection from SEAH (CAPSEAH) in collaboration with the Steering Committee and large consultative network to drive more progress and alignment across international standards. This work will continue, alongside our core safeguarding programmes and commitments made as a donor at the 2018 London Summit and the 2020 UK Strategy.

Annex A: Progress with implementing the UK strategy: Safeguarding against SEAH within the aid sector

This framework provides headline results indicators to track implementation and overall direction of travel as ODA spending departments implement the 3 pillars of the September 2020 UK Strategy. It uses a BRAG^{[footnote 3]} rating against the strategy’s high-level monitoring framework and gives examples. While individual ODA-spending departments are accountable for their own spend, and responsible for tracking detailed progress against relevant commitments made in the Strategy and for reporting, as appropriate, to their own internal and external accountability bodies, the indicators below have been selected to provide a high-level summary of progress. The page reference for each commitment from the strategy is given in the first column.

Pillar 1: Delivering sector-wide change including support to survivors and greater accountability

Safeguarding strategy commitment	Results indicator	BRAG	Progress	Example
1.1 Provide leadership	Continuing to convene donor Technical Working Group and the Cross Sector Safeguarding Steering Group (CSSG) quarterly and publishing annual progress reports. Continue to co-chair the DAC SEAH Reference Group	Green: Action is on track	All indicators on track	FCDO continued to convene those groups and the CSSG report is expected to be published by January 2024
1.2 The UK will put measures in place to make it much more difficult for perpetrators to escape justice, make it easier for organisations to have confidence in those they recruit and allow communities to have confidence in the people sent to help them	3 Employment cycle programmes operational	Amber: Action mainly on track with some minor issues	Work continuing with good progress on 2 and slower progress on one	Over 220 organisations have now signed up to the Misconduct Disclosure Scheme funded by FCDO, which has prevented over 230 posts from being filled due to identified safeguarding risks to date. Project Soteria with Interpol is operational and has run workshops for law enforcement agencies and development partners in the Philippines, Nepal, Bangladesh, Kenya, Tanzania, Uganda, and Moldova. The pilot of the Aid Worker Registration Scheme has been paused for now to assess if there is still enough value and appetite
1.3 The UK has endorsed international minimum standards on SEAH and supporting organisations to verify adherence to the IASC on PSEA and/or the CHS. We will work with other donors to agree alignment with these standards and ensure adherence through our respective funding agreements and due diligence assurance arrangements	All our funding agreements reflect the agreed donor language	Amber: Action mainly on track with some minor issues	Work continuing with progress made compared to last year	FCDO continued to work closely with donors to agree SEAH language for use in UN funding agreements. FCDO issued a letter on aligned donor language on SEAH for International Financial Institutions (IFI), which included signatures from other donors and IFI shareholders. A larger number of funding agreements reflect the agreed language, but not all just yet FCDO also continued to support the Humanitarian Quality Assurance Initiative (HQAI), as an independent auditor that certifies aid sector organisations’ adherence to the Core Humanitarian Standard (CHS) on Quality and Accountability, and thereby build good practice, transparency and accountability across the sector. With ambition to create a critical mass of users, HQAI offers the potential to reduce inefficiencies in the aid sector through reducing the need for multiple donor accountability processes. FCDO engaged in pilots to test the potential of bridging donor due diligence requirements (including FCDO’s own) with the CHS audit both at national and international level with results expected by the end of 2023
1.4 Survivors and victims will be responded to with respect, confidentiality, safety and non-discrimination	Departments can point to examples/evidence of procedures and anonymised cases if asked	Green: Action is on track	Work continuing with progress made since last year	Ministry of Defence (MOD) continued to improve reporting mechanisms so personnel feel safe in raising issues and confident that their evidence will be acted on. Complaints of bullying, harassment or discrimination are dealt with by someone outside an individual’s chain of command, and the introduction of zero tolerance policies, strengthen the levers available to dismiss or discharge anyone who has committed a sexual offence or other unacceptable behaviour. In 2023, MOD rolled out a Centralised Sexual Harassment Survey to actively seek the opinions of Service Personnel and to feed into the development of education and policy to reduce unacceptable sexual behaviour
1.5 Hold ourselves to account for delivering this Strategy through transparent reporting in our Annual Reports, scrutiny from the UK’s Independent Commission on Aid Impact and relevant committees of the UK Parliament, internal management and board oversight, and periodic public reporting against the 2018 London Safeguarding Summit commitments	Include text on safeguarding as part of annual report to Parliament/public on ODA activities	Amber: Action mainly on track with some minor issue	Work continuing	See most recent annual FCDO report

Pillar 2: Delivering organisational change within UK aid spending departments

Safeguarding strategy commitment	Results indicator	BRAG	Progress	Example
2.1 We will ensure that all departments have a clear staff code of conduct in place, making it explicit what behaviour is expected of staff	Codes of conduct explicitly prohibits ODA staff from paying for sex in every ODA spending department	Green: Action is on track	Work continuing with good progress made.	Department for Energy Security and Net Zero (DESNZ) has a clear code of conduct held in the International Climate Finance (ICF) Safeguarding hub. Staff are also reminded regularly of the expectations regarding Sexual Exploitation, Abuse and Harassment via training sessions
2.2 Well-signposted reporting mechanisms for staff to raise concerns and robust procedures for handling them	Whistle-blowing and reporting and complaints mechanisms are in place, proactively advertised and reporting figures show they are used	Green: Action is on track	Work continuing with progress made	New Department for Environment, Food, and Rural Affairs (DEFRA) Safeguarding Policy includes guidance to report all cases immediately to a dedicated mailbox. This has been communicated to ODA staff through training Reported cases are managed as set out in a case management flowchart, including a dedicated safeguarding resource to manage and provide oversight of any cases
2.3 All departments will have a named safeguarding lead to set the tone from the top, including regular messaging out to staff about the importance of the agenda and at least annual discussion at Board level	Named safeguarding Champion in all departmental Senior Leadership teams Annual Board discussion on Safeguarding against SEAH	Green: Action is on track	Work continuing with good progress made in several departments	Department of Health and Social Care (DHSC) has a named ODA safeguarding champion, the head of ODA effectiveness who sits in Senior Leadership Team At the Global Health Security Programme Board, they have annual papers on safeguarding to update on progress and discuss any further steps which need to be taken DHSC’s research delivery partner, the National Institute for Health and Care Research (NIHR), provides an annual report of all incidents reported through the NIHR Incident Reporting Form to DHSC’s Science, Research and Evidence Directorate Senior Management Team. This process has been incorporated into wider NIHR policy on Preventing Harm in Research, applicable to all NIHR contracts
2.4 Risk Management processes prioritise prevention and response to SEAH	Department level risk management framework for ODA spending includes SEAH	Amber: Action mainly on track with some minor issues	Work continuing with good progress made in several departments	SEAH is embedded into Defra’s ODA risk management frameworks and guidance, which has been updated during the year under review. Defra’s risk approach to SEAH is focused on 2 pillars – both prevent and respond

Pillar 3: Delivering programmatic change across UK aid programmes

Safeguarding strategy commitment	Results indicator	BRAG	Progress	Example
3.1 Applying the Due Diligence Assessment: The Due Diligence Assessment of all UK Aid partners has been strengthened and their performance on safeguarding against sexual exploitation abuse and sexual harassment will continue to be assessed in 6 areas to ensure they meet the standards we require	Due Diligence assessments of partner organisations includes thorough assessment of the UK’s 6 SEAH standards, and this is universally conducted for all partners prior to entering into a funding agreement	Green : Action is on track	Work continuing with progress made	Home Office Modern Slavery Fund partners are regularly assessed against the UK’s 6 SEAH standards. The Safeguarding Advice and Children’s Champion (SACC) holds regular 1-1’s with partner organisations to assess their level of commitment to safeguarding. Due diligence assessments include the 6 SEAH standards
3.2 The UK will continue to mainstream safeguarding against sexual exploitation and abuse and sexual harassment throughout our programme cycle, using tendering processes, design phases, risk assessments and risk management, regular reporting, routine monitoring and evaluations to assess the implementation of safeguarding standards at the delivery level	Number of cases of SEAH reported through ODA programming is internally reported to the board at least annually and patterns and challenges are discussed, and processes refined to address concerns within the programme management cycle	Amber: Action mainly on track with some minor issues	Work continuing with progress made in some departments	FCDO report case numbers to each Board meeting with discussion of patterns at least annually
3.3 Provide resourcing to partners where needed to ensure that their programmes and delivery chains prevent and respond to sexual exploitation and abuse and sexual harassment in a victim and survivor-centred way	Departments can point to examples of requests made and approved	Green: Action is on track	Departments able to point to examples in the past year	The Department for Energy Security and Net Zero – International Climate Finance team has developed safeguarding guidance for delivery partners to help them ensure safeguarding principles are adhered to. In other cases, DESNZ ICF team has actively supported delivery partners in developing their own safeguarding policies by sharing best practice from other partners with them

Annex B: The donor commitments from the 2018 London Safeguarding Summit which this document is reporting against

Strategic shift 1: ensure support for survivors, victims and whistle-blowers; enhance accountability and transparency; strengthen reporting; and tackle impunity.

1. Wherever possible actively include beneficiaries in the design, implementation and refinement of programmes and improved complaints and feedback mechanisms that will empower individuals to come forward with the confidence that they will be heard, that their concerns will be fairly pursued, that feedback will be provided to them as soon as possible and that their safety will be of the utmost concern.

2. Clearly communicate requirements and best-practice guidance for the reporting of incidents, and work towards aligned reporting practices and the sharing of information. Considerations of confidentiality, the protection of relevant individuals, and relevant

Legislation will be central to this work

3. Review, and where necessary, renew efforts within and between aid agencies and across governments and the wider international system, to avoid the hiring and recirculation of perpetrators in the aid sector, and to hold them to account, including by helping to bring them to justice, when appropriate, all in line with due process and relevant legal obligations.

4. Ensure that relevant information about allegations, confirmed cases, prevention measures and response activities, are an integral part of reporting mechanisms, which for some donors will include annual public statements. The confidentiality of information and the safety of individuals will be paramount.

5. Adopt a victim/survivor-centred approach to help victims and survivors to access tangible and practical help to recover from the effects of abuse, exploitation and harassment, for example, by supporting the work of the United Nations’ (UN) Office of the Victims’ Rights Advocate (OVRA) and the UN Victims Support Trust Fund.

6. Review best practice and lessons from ombudsman schemes to explore the potential to improve systems of complaints mechanisms, referral pathways and independent accountability.

Strategic shift 2: incentivise cultural change through strong leadership, organisational accountability and better human resource processes

7. Have one or more named senior-level champion(s) accountable for work on sexual exploitation and abuse and sexual harassment, while stressing that the responsibility for safeguarding rests with all individuals in an organisation.

8. Encourage at least annual discussion at the Board or equivalent level in all organisations of sexual exploitation and abuse and sexual harassment and how the organisation is addressing them.

9. Encourage the recruitment and career development of women at the senior management level and throughout organisations to send a clear signal about the importance of gender balance and a diverse and inclusive workforce.

10. Review, and where necessary, strengthen recruitment and referencing processes to build workplace cultures of respect and accountability, and so help prevention.

11. For members of the UN Secretary General’s Circle of Leadership and signatories to the Voluntary Compact, encourage other Member States to join this collective statement of intent, and encourage a review of progress within the next 12 months.

12. Encourage delivery of the UN Secretary-General’s 2017 Special measures for protection from sexual exploitation and abuse strategy through joint donor messaging that recognises the need for related action plans with clear deliverables and milestones from each relevant UN organisation. Encourage the International Financial Institutions to deliver on the collective and individual commitments they have made, and ensure the monitoring of implementation.

13. Those members of the donor group who participate in the Multilateral Organisation Performance Assessment Network (MOPAN) will support and advance the discussion on enhancing assessment in relation to sexual exploitation and abuse and sexual harassment to help the improved effectiveness of multilateral organisations.

Strategic shift 3: Adopt minimum standards, and ensure we and our partners meet them

14. Demonstrate adherence to one or both sets of international minimum standards related to preventing sexual exploitation and abuse (PSEA), namely the Inter-Agency Standing Committee Minimum Operating Standards on PSEA, and/or the PSEA elements of The Core Humanitarian Standard on Quality and Accountability. In the longer term, we will look to review and strengthen measures for verification of that adherence, and how the standards could also cover sexual harassment.

15. Review, and where necessary, strengthen formal funding templates and due diligence tools to reflect those standards, and include clear and specific language on sexual exploitation and abuse and sexual harassment, including common definitions. This also includes reviewing, and, where necessary, strengthening, language for our funding partners which requires them to apply the same minimum standards in their sub-granting and contracting requirements for downstream partners.

16. Review and, if necessary, revise project monitoring arrangements (eg frequency, scope and indicators), to ensure a stronger focus on sexual exploitation and abuse and sexual harassment issues.

17. Support the OECD Development Assistance Committee (DAC) to formulate a new DAC instrument that in 2019 will set standards on preventing and managing the risks of sexual exploitation and abuse in development cooperation, and drive donor accountability in meeting them.

Strategic Shift 4: Strengthen organisational capacity and capability across the international aid sector, including building the capability of implementing partners to meet the minimum standards

18. Review and if necessary strengthen core oversight and management systems for tackling sexual exploitation and abuse and sexual harassment, and use victim/survivor-centred responses.

19. Explore options for a Resource and Support Hub to develop and communicate the evidence base, best practices and guidance on tackling sexual exploitation and abuse and sexual harassment, with a focus on providing support to smaller organisations.

20. Provide guidance and minimum training requirements for relevant staff on the prevention of and response to, sexual exploitation and abuse and sexual harassment.

Next steps

21. Each of us commits to taking action on the above through our own systems, processes and stakeholders, as consistent with relevant domestic and international law, and taking into consideration relevant existing structures and operating models. It is up to each of us to decide which measures are the most urgent and how we will communicate progress to our stakeholders.

22. We will meet no later than 12 months from now to assess progress, while continuing to liaise regularly to keep up the pace of progress and share lessons on this vital issue.

1. Numbers refer to the commitment number out of the 22 made by donors in 2018. ↩

2. SEAH elements of the Core Humanitarian Standard (PDF, 1.4 MB), and Interagency Standing Committee (IASC) Minimum Operating Standards for PSEA (PDF, 861 KB). ↩

3. BLUE: Action is complete; RED: Action not on track with major issues; AMBER: Action mainly on track with some minor issues; GREEN: Action is on track. ↩