Appendix 1 - Executive Summary of report by GCPS Consulting, dated 10 December 2020

Question 1

Acknowledgements

Accepted Answer

The GCPS Review Team would like to thank all of the Oxfam staff and Officers that supported this review, as well as those external to the organisation that provided valuable information and assistance.

In particular, we would like to acknowledge the work of Judeth Neville, Head of Governance, for supporting the review process and ensuring, along with Clifford Isabelle and his colleagues in the Global Safeguarding Team, that evidence was available to the team and clarifications and explanations were always forthcoming.

A special mention must also go to Nicola Mitchell for uploading and organising the evidence in a way that greatly facilitated the review.

We are also extremely grateful to Harvey Grenville and Wei Feng Lee at the Charity Commission for skilfully guiding and supporting the review process.

Question 2

Background and overview

Accepted Answer

Following media coverage in 2018 of weaknesses in Oxfam GB’s (Oxfam’s) safeguarding practices, the Charity Commission of England and Wales (the Commission) opened a statutory inquiry into Oxfam, in particular its approach to safeguarding.

As part of Oxfam’s response to the inquiry, its Trustees commissioned Ineqe Group Ltd (Ineqe) to conduct an independent external review of Oxfam’s past safeguarding case management (2011-March 2018) and of its safeguarding practices as of March 2018.

The Commission and Ineqe reports were published on 11 June 2019. The Ineqe report made 79 recommendations. Of the total of 79 recommendations, Oxfam asserted to the Commission that it had completed 67 on or before 11 June 2019.

On 10 June 2019, the Commission made an order under section 84 of the Charities Act 2011 requiring Oxfam to submit for the Commission’s approval, an action plan (the Action Plan) setting out the reasonable steps by which Oxfam would, acting in the best interests of the Charity, implement:

outstanding actions relating to recommendations made by Ineqe
the actions that Oxfam and/or its trading arm identified should be taken to adequately address the safeguarding risk management and assurance matters in respect of Oxfam’s UK shops in the Commission’s inquiry report
and relevant matters arising for Oxfam from the final recommendations and findings of the Independent Commission on Sexual Misconduct, Accountability and Culture established by Oxfam International

All actions were due to be completed by 31 March 2020.

Concurrent with the requirement of the section 84 order that there be verification work undertaken to provide assurance on the implementation of the action plan, Oxfam was also committed to maintaining its accountability to the public and other key stakeholders; as soon as practicable after 31 March Oxfam’s trustees wanted to assure themselves, the Commission and other stakeholders that Oxfam had completed the Ineqe first tranche recommendations and the actions set out in the Action Plan.

Oxfam’s trustees and the Commission agreed that the best method of assurance was to commission an independent assessor, to be selected by agreement between Oxfam and the Commission following a robust selection process. The Independent Assessor would conduct an assessment in accordance with agreed terms of reference and methodology.

GCPS Consulting was selected as the Independent Assessor end of March 2020 and began work on the Review on 2nd April 2020 via an Inception Meeting involving Oxfam and Charity Commission colleagues to clarify and agree aspects of the terms of reference, methodology and plan the detail of the work (see section below on ‘Methodology’ for details).

Question 3

Scope

Accepted Answer

The requirements of the Assurance Review were for GCPS to assess, and report in writing to Oxfam’s trustees and the Charity Commission on the extent to which Oxfam (including where appropriate its trading division) had undertaken effective and proportionate actions relating to the specific recommendations and action points.

Where GCPS considered Oxfam had not fully implemented any recommendation or action, GCPS was to assess and report in writing on the sufficiency of any actions Oxfam may have taken in place of implementing the recommendation or action.

Also, where appropriate or necessary, GCPS was to make recommendations to the trustees and the Commission on any remedial actions required to address any identified gaps or weaknesses in the actions which Oxfam has taken.

It was agreed from the outset that the exercise should not be conducted as a wide-ranging review of Oxfam’s safeguarding arrangements as currently constituted, or for the Assurance Review to introduce additional standards or good practice elements beyond those required by the previous reports, but rather it should be a focused assessment looking at the detailed work done to meet the specific recommendations and action points from the previous reviews.

GCPS has been disciplined in not straying beyond the bounds of the Assurance Review, but would like to take this opportunity to recognise the work that has been done by Oxfam over the past two years in relation to its safeguarding framework and overall approach, and certainly subsequent to the previous reviews.

This GCPS independent assurance review will affirm that Oxfam has satisfactorily attained the overwhelming majority of the 100 recommendations and commitments in the Ineqe review and the Action Plan, with only four areas of exceptions to be addressed and some strengthening still required in areas not fully met (see Table 1 below). Nevertheless, these should be put into perspective and into the context of the enormous collective efforts that have resulted in substantial changes to the way Oxfam approaches safeguarding.

Areas that still require improvement should also be balanced against themes that demonstrate robust good practice such as Risk Management and Governance.

Table 1: Attainment scores by theme

Theme	1 Score	2 Score	3 Score	N/A*
Strategy & Planning (6)	0	2	4
Systems & Procedures (8)	0	1	5	2
Risk Management (6)	0	0	6
Recruitment, Vetting & Performance Management (14)	1	1	12
Capability & Capacity (26)	2	9	15
Case management (26)	0	9	17
Serious Incident Reporting (7)	1	2	4
Governance & Accountability (7)	0	1	6
Total 100	4	25	69	2

*^{[footnote 1]}

It appears Oxfam has made many significant strides over the past two years or so on its safeguarding journey and the small number of gaps highlighted by GCPS in this report should be seen as positively contributing to the continued development of safeguarding in Oxfam, rather than any signs of fundamental weakness in current arrangements.

Although not part of the brief for GCPS, it is important for us to recognise the work of Oxfam, its trustees and leadership, the Global Safeguarding Team and many other colleagues in transforming the safeguarding arrangements. Examples of practical measures that have made a positive impact described in the report include:

leadership including recruitment of a Lead Safeguarding Trustee chairing a Council Safeguarding & Ethics Committee, and recruitment of Global Safeguarding Director
increased investment in safeguarding and the Global Safeguarding Team
safer recruitment – with focus on safeguarding at every stage of recruitment and induction
increased emphasis on a survivor centred approach
robust case management processes, with the additional assurance of regular external audits
work to develop improved and appropriate reporting mechanisms
safeguarding throughout the programme cycle – the implementation of a Safe Programmes Framework and of safeguarding risk assessments for every project and programme

The most encouraging aspects of the changes, apart from these and other very practical measures that have been developed, strengthened, or newly deployed, are the adoption of a ‘maturity model’ and ‘continuous improvement’ model by the organisation. These reflect not only the ongoing commitment to this work, but also a change in mind-set of Oxfam and a greater humility in accepting that much work still needs to be done.

There is no ultimate end point for safeguarding whereby an organisation can say the work is complete, rather an acknowledgement there is always a need to learn, adapt and develop to better meet existing and new challenges and continue to address ongoing and emerging risks and issues. It is evident to the review team that Oxfam is now much better placed to continue on this journey.

Question 4

Methodology and explanation of scoring system

Accepted Answer

GCPS developed a thematic approach to review the 79 Ineqe recommendations plus the additional 21 actions committed to by Oxfam in their 3-part Action Plan. The recommendations and actions were grouped into thematic areas as detailed below and ordered to reflect a safeguarding structure that encompasses key organisational building blocks of a robust prevention and response system supported by governance and accountability arrangements.

Strategy and Planning
Systems and Procedures
Risk Management
Recruitment, Vetting and Performance Management
Capability and Capacity
Case Management
Serious Incident Reporting
Governance and Accountability

Means of verification and extensive evaluation criteria were developed for each thematic area. To establish the degree to which findings against the recommendations were attained, a scoring system with explanation of assessment outcomes (0-3 ratings) was designed (see Table 2 below and “Explanation of Scoring System” at end).

Table 2: Explanation of scoring

Rating	Attainment	Assessing Adequacy of Actions	Evaluations Considerations
0	Not Met	No evidence	No evidence or evidence does not indicate the recommended has been addressed in any way.
1	Part Met	Some evidence	Some evidence that an attempt or some effort has been made to address the recommendation, but the action does not go far enough or is inadequate to a large degree.
2	Largely Met	Evidence of serious/sustained effort	evidence that serious/sustained efforts have been made to address the recommendation, but there is still some gap/remaining action required or the action taken does not go far enough or is inadequate to some degree.
3	Met	Fully met	Evidence of adequate actions to meet the recommendation in full.

NB: So called ‘binary recommendations’ (yes/no) should be either 0 or 3 rating.

This scoring system was developed to allow a more nuanced approach to assessing the completeness of Oxfam’s responses to recommendations and action points, beyond a simple ‘met/not met’ binary outcome (although some recommendations were classified as such). GCPS regards scores of 2 or 3 to represent satisfactory outcomes and demonstrate those recommendations and action points are fully or largely met.

There is reference in the text to ‘gaps’ and ‘exceptions’. As noted in Table 1 above, there are only four exceptions whereby a recommendation is deemed not to have been satisfactorily attained (these score 1, rather than 2 or 3). Where a response to a recommendation scores 2 rather than 3, we also refer to gaps, by which we mean further action is required to ensure full attainment (a 3 score). Use of the term ‘gaps’ in these instances does not mean recommendations have not been satisfactorily attained.

The GCPS Review Team conducted a thorough review of almost 3,500 documents supplied by Oxfam. The desk review included a wide range of documents from Oxfam GB and Oxfam International as well as from across different business functions and geographies.

A representative sample case review was also undertaken to verify/assess the application of case management procedure to practice. This part of the review looked at international and UK cases covering the time period of June 2019 to March 2020. Cases were selected using criteria identified by the GCPS Review Team.

The substantive desk review involved a thorough assessment of evidence provided by a range of Oxfam teams, including Safeguarding, Trading, People and Governance Teams, and ongoing dialogue with the Oxfam Global Safeguarding and Governance Teams seeking clarifications and requests for additional evidence to inform assessments.

A robust quality assurance and moderation process on evidence was established by the GCPS Review Team in order to ensure both validity and reliability of findings.

Question 5

Executive Summary (summary findings by thematic area)

Accepted Answer

Strategy and planning

This thematic area addresses six recommendations related to Oxfam’s safeguarding arrangements in the context of its strategy and action planning – four were fully attained and two require some further action.

Majority attainment is demonstrated through the formulation of a 2020 refresh safeguarding strategy. A comprehensive consolidated 3-part report provides clear objectives, tracks progress and between June 2019 and March 2020 Oxfam used this to update the Charity Commission on progress of actions being taken in response to the Independent Safeguarding Review and Action Plan. Progress was also reported to and discussed with the Safeguarding Trustee Subgroup and at each quarterly Council meetings.

The training commitment up to June 2021 is for 80% of staff to have received some form of safeguarding training linked to their role. There is also a detailed draft Learning and Development Strategy 2020-2022.

Oxfam has adopted a Standards Based Maturity Model to reinforce and underpin its safeguarding strategy. And a number of critical processes are in place to underpin the implementation of the model.

While comprehensive work has been undertaken in the area of strategy and planning, the development of a formal Evaluation Framework recommended by the Independent Review to determine impact remains a gap. This finding has been accepted by Oxfam.

Systems and procedures

This thematic area addresses eight recommendations concerning the development and implementation of safeguarding policies. There were no exceptions and Oxfam achieved full attainment against five of these, one area contained a gap, and two were deemed not applicable as they are beyond Oxfam control.^{[footnote 2]}

All relevant policies have been updated, and the Safeguarding Children Policy includes a statement qualifying overarching accountability with the CEO and Chair of Trustees sending a clear message to all staff, volunteers, beneficiaries and stakeholders on organisational priority and responsibility.

All policies have a clear implementation plan and so meet previous review requirements and demonstrates a commitment to ongoing evaluation and continuous improvement. The plan also includes dissemination and training information and provides assurance that all staff will receive the requisite safeguarding input to support implementation and safeguarding compliance.

It was recommended by the Ineqe Review ^{[footnote 3]} that Oxfam include a specific statement in the PSEA Policy in the section dealing with reporting safeguarding cases to the statutory authorities to clarify that reporting considerations also apply where there is “potential risk of harm”. The PSEA Policy is an OI document and Oxfam’s position within the broader Oxfam confederation places a constraint on unilaterally amending an agreed OI document. However, Oxfam has accepted the required amendment and is taking action to address this.

Recommendations that advised specific amendments to the Code of Conduct presented a similar structural constraint, as it too is an OI document. As with the PSEA policy, Oxfam has accepted the Ineqe recommendation in full ^{[footnote 4]}, acknowledging the importance of embedding responsible behaviours and conduct, evidencing this through an Oxfam targeted training programme.

Risk management

The GCPS Independent Review Team assessed 6 specific actions in this thematic area; there were no exceptions. There was solid evidence of adequate action to meet all actions in full validating this as an area of significant improvement and strength.

Oxfam’s safeguarding Action Plan describes actions that its Trading arm is committed to take to adequately address safeguarding risk management and assurance matters in respect of Oxfam’s UK shops. At the time of this Review ^{[footnote 5]}, Oxfam’s Trading Arm internal audit programme is adequately resourced. All overdue audits have now been completed^{[footnote 6]}.

Quarterly safeguarding assurance reports throughout the 2019/20 reporting year were produced for the Trading Lead Trustee and Leadership Team which specified issues and risks, shop compliance rates and provided an analysis of performance.

Although even before 2018 the policy was clearly that a Registered Sex Offender (RSO) could never work or volunteer, Oxfam Trading has strengthened its policy and guidance regarding suspected RSOs. All measures have been taken to ensure that no RSOs are recruited.

Discernible efforts have been made to communicate the importance of worker risk assessments and to improve compliance in this area. The Trading leadership expressed commitment to driving this forward in setting a 95% compliance target rate and reinforcing the need to make sure risk assessments are completed carefully and thoroughly. In December 2019, a 93.2% compliance rate had been obtained.

Outside of the Oxfam Trading Arm, the GCPS Review Team also reviewed wider Oxfam risk management actions arising from the final report recommendations and findings of the Independent Commission ^{[footnote 7]}. It is evident that Oxfam has strengthened its mandatory safeguarding risk assessment and mitigation planning in International Programmes. Comprehensive guidance and training for staff now exists to help them better understand and manage safeguarding risks. The Review recognises that Oxfam has developed a Safe Programmes Framework to ensure safeguarding is considered in the design, delivery, and monitoring of programmes.

Recruitment, vetting and performance management

The Review Team assessed 14 recommendations/actions for this thematic area. The Review saw substantial evidence of good practice and improvement; there is only one exception to report against where the action taken was inadequate.

Recruitment and vetting

Oxfam has taken a number of critical steps to strengthen and improve safer recruitment. These include the revision of the Recruitment Policy in late 2018; the development and integration of safer recruitment minimum standards; and the introduction of mandatory safeguarding questions when seeking to appoint.

Furthermore, it is a requirement to take up a minimum of two references prior to offering a job to external applicants, and comprehensive guidance is in place on reference requirements more generally ^{[footnote 8]}. It is also a requirement to obtain a new DBS check at enhanced level or equivalent ^{[footnote 9]} for every new member of staff who works directly with, or has regular contact with, children or vulnerable adults in the UK.

Outside the UK, Oxfam is seeking ‘local checking services, for example Police records’ ^{[footnote 10]} for local hires and has signed up to the Inter-Agency Misconduct Disclosure Scheme ^{[footnote 11]}. Internal candidates are also subject to a safeguarding and counter fraud check.

The exception in this area relates to the recommendation that Oxfam should include the regular use of the International Child Protection Certificate (ICPC) as part of its recruitment process overseas ^{[footnote 12]}. The ICPC ^{[footnote 13]} is a type of criminal record check for UK nationals, or non- UK nationals who have previously worked in the UK and are seeking to work with children overseas. Oxfam considered implementing the ICPC but decided not to adopt it; however, this decision was reversed in May 2020 during the course of this Review on advice of GCPS.

Oxfam GB Shops

Although recognised as an example of good safeguarding practice, including in its hiring practices, The Ineqe Review ^{[footnote 14]} defined specific recommendations for Oxfam’s Trading Arm to further strengthen safe recruitment of both staff and volunteers for Oxfam’s UK shops.

Oxfam Trading has strengthened its policy and guidance regarding suspected RSOs who might attempt to volunteer in shops. All measures have been taken to ensure that, in accordance with Oxfam’s policy (pre-dating 2018), no RSOs are able to volunteer.

Trading is ensuring the completion of worker risk assessments and that adequate arrangements are in place to risk assess volunteers who are engaged via Community Service Orders. There is clear procedural guidance to ensure no-one under 18 can work in the shop unless there is a DBS vetted adult supervisor on duty.

Culture and performance management

There is evidence that Oxfam has made significant efforts to improve its culture and performance management since 2018. Oxfam has demonstrated a clear commitment to actively recruit women to positions of power and influence to address gender balance at the top of the organisation. In 2016, women represented 25% of the leadership team and as of 2020, this had increased to 45% . ^{[footnote 15]}

Oxfam International changed its performance management in 2019; it has produced clear guidance and minimum standards based on good practice and feminist leadership principles.

Increased capability and capacity

Altogether, there are twenty-six recommendations across the two strands in this thematic area and Oxfam achieved full attainment against 15 of these. There are 2 exceptions and 9 areas that contain some gaps.

Capability

Sustained effort to ensure the capability of its Safeguarding Team has been made including bringing into the organisation appropriately qualified social work professionals at leadership and management levels, and the review team has seen evidence of a programme of safeguarding training delivered during 2019 and early 2020 to target groups in a number of high-risk countries.

Trading staff have also received safeguarding training with particular concentration on referral thresholds and the role of the Local Authority Designated Officer (LADO).

Furthermore, to satisfy a recommendation targeting Oxfam shop managers, specifically their recruitment and management of volunteers, an impressive target of 32 training sessions was met with training being delivered at every area meeting by March 2020.

In the period since the Ineqe Review ^{[footnote 16]}, there is evidence that serious and sustained efforts have been made by Trustees to develop and extend their safeguarding capability and work has begun on developing individual Trustee Personal Development Portfolios. How these relate to their individual role in Oxfam, however, should be included in order to establish a base line of knowledge and understanding across the Council linked to relevant areas of Trustee role responsibility.

A further recommendation of the Ineqe Review to explore shadowing opportunities for Trustees was considered by senior Oxfam managers in consultation with the Director of Safeguarding. However, on the advice of the latter, for data protection; confidentiality and capacity within the relevant law enforcement and social services agencies, this was not pursued.

Oxfam has not developed its own in-house e-learning package but instead has set up links to external resources on Safeguarding & PSEA for staff to complete as part of their mandatory training. Building in tests as part of the e-learning and prescribing a mandatory pass rate remains a gap. Additionally, no sample completed tests and results or information about compliance rates were provided.

While there is evidence, of training being delivered to different audiences across Oxfam and much of it to a high standard, the recommendation to develop a defined programme of training, scheduled to run annually, published in advance and planned in a systematic way that maximises attendance, remains a gap.

Capacity

Since the Ineqe Review reported in 2018 Oxfam GB has made the necessary investment to ensure the Global Safeguarding Team is sufficiently resourced and equipped to satisfy its functions and responsibilities across Country Offices, and its UK offices and functions, including its Trading Arm.

A comprehensive programme of training for focal points to establish and maintain an effective Oxfam safeguarding network is well under way, and while the aim to deliver further training to Country Directors this year has been impacted by the recent Covid 19 pandemic, a working party is in place to address this.

There is evidence of a comprehensive overarching ‘One Oxfam Safeguarding Learning and Development strategy 2020 – 2022’ which (although still in draft) includes a training needs assessment and analysis for most of the organisation and sets out clear organisational safeguarding training priorities, however a consolidated (‘one process’) Learning and Improvement framework remains a gap

The Global Safeguarding Team has developed pre-and post-training surveys to guide country training delivery and attention to capacity building in the area of safe programming and community engagement evidences an Oxfam cross cutting commitment to a survivor centred approach, inclusive values and developing local accountability.

Oxfam has produced a feminist leadership behaviour framework and a supporting document which details how to share power and challenge behaviour. Additionally, Oxfam has developed cultural workshops which enable staff to explore different aspects of culture and power.

Robust assurances have been provided by the Director of Safeguarding that there is sufficient resource within the current team to carry out investigations as well as to undertake the necessary training and preventative work. Based on this assurance and evidence of the improved capacity and capability of the team, including safeguarding advisors based locally and in Regions, full attainment against the recommendation has been achieved.

A recommendation for Oxfam to engage other cross-agency forums to explore opportunities to develop the role of the Regional Designated Officers (RDO) on a cross-NGO basis has not yet been achieved.

There is evidence of serious and sustained efforts to develop a consolidated and comprehensive Learning and Improvement Framework recommended by the Ineqe Review, although it is unclear how this is being done in practice outside of case auditing. Safeguarding self-assessments have been used to assess gaps in 19 countries but it remains unclear how this information was used to inform institutional knowledge and learning. Additionally, no information has been provided on how Oxfam will use stakeholder feedback and external learning.

An Ineqe Review recommendation that Oxfam GB develop a single course structure, applicable across all of Oxfam divisions, both in the UK and in the EA is considered a gap by the GCPS Review Team.

Although there is evidence of serious and sustained efforts, there is no clear demonstration that Oxfam has developed a safeguarding training evaluation framework. It was also unclear if Oxfam has a systematic approach to the evaluation of safeguarding trainings or clarity on how it is routinely collating and analysing evaluation feedback to feed into institutional learning. It also remains uncertain if consideration was given to a dedicated resource to manage this activity.

The Ineqe Review recommendation to develop an Effectiveness Review that includes safeguarding as a defined element or as a stand-alone discipline, is considered by the GCPS Review Team as an exception.

A further area of exception is the absence of a formal Learning Management System, recommended by the Ineqe review based on the absence of a central record which in their view hindered Oxfam’s ability to have a clear oversight on training delivery across its UK and international workforce. The ability for the system to deliver specific prompts for refresher training is central to the recommendation.

Oxfam has given assurance that improvements are being worked on to address the shortfalls.

Case management

This thematic area addresses twenty-six recommendations that relate to four sub-topics: case management procedure and practice; investigations; historic case work and reporting to the police and other relevant agencies. There are no exceptions in this thematic area and Oxfam achieved full attainment for seventeen of the recommendations. The remaining nine of the recommendations were largely met, as there was evidence of serious and sustained efforts being made, but some gaps were identified.

In general, Oxfam has demonstrated significant improvements to reporting and case management practice. The Global Safeguarding Team has strengthened its capability through the hiring of qualified professionals with advanced case management and investigation experience and skills. Oxfam has also commissioned an external company, Girling Hughes Associates, to proactively conduct periodic case review audits to identify gaps and ensure continuous learning. Oxfam has committed to continuing with annual case review audits. Overall, these reports indicate steady improvements in Oxfam in terms of case handling.

Case management procedure and practice

Oxfam has taken robust steps to strengthen case management practice. New procedural documents are in place and complemented by a comprehensive suite of case management resources that ensure in safeguarding cases, investigators and decision makers seek early advice from the Global Safeguarding Team. Management and oversight of information relating to the tracking of cases and the monitoring of actions have been put in place and formal review periods are captured in clear case timeline targets. To help ensure sufficient organisational awareness of procedures and accompanying guidance, Oxfam has committed resources to training safeguarding focal points globally as they act as the first point of contact for any reports.

Oxfam has recognised the importance of having a strong case management and user-friendly system by investing in the acquisition of CLUE case management system which is advanced investigation and intelligence software.

Whilst recent Oxfam endeavours have resulted in significant progress and strengthened practice interventions the GCPS Review Team identified some areas where further action is required:

Decision making process – rather than the existence of a specific and streamlined template (checklist) to aid effective decision making and a contemporaneous record, several forms exist which are dispersed across the case management suite of resources
The Consolidated Safeguarding Case Management Standard Operating Procedure (SOP) does not explicitly align with a UK ‘best practice’ approach set out in statutory and non-statutory guidance in the UK
The Consolidated Safeguarding Case Management SOP does not include an explicit reference in any of the process steps to a safeguarding incident being a potential crime or constitute criminal activity, and so there is no reference to considering an external referral to the police or other appropriate agencies, although the requirement to consider an external referral is clearly set out in in the template agenda for the first stakeholder meeting and actual practice appears to be that this is always a consideration
The Review Team were unable to determine if Regional Designated Officers (RDOs) and other relevant decisions makers, critically members of the Incident Management Panel (IMP) have been sufficiently trained on case management and the Consolidated Procedural Guidance document

Investigations

The Review Team found evidence that Oxfam has taken steps to improve investigation practice. This was substantiated in the Phase 3 Girling Hughes report ^{[footnote 17]} which observed “the quality of the investigations that have been reviewed in this phase is greatly improved compared to the previous phases”.

The One Oxfam Safeguarding Case Management SOP clearly states that investigations should be carried out by professional/trained investigators with experience in the field of sexual exploitation, abuse and harassment (SEAH) and that investigations into allegations of child abuse must be conducted by specialist investigators in recognition of the risks involved.

Investigation management procedure and resources make provision for check points and reminders to ensure decisions are made about several key considerations at the earliest possible stage

An issue for the GCPS Review Team in this sub-topic area relates to independent investigators. Whilst the Safeguarding Case Management SOP allows for the appointment of independent investigators, it does not go far enough. The SOP do not state explicitly that the use of independent investigators should be considered for all cases involving individuals in positions of power, influence, and authority. Again, the GCPS Review Team was assured that in practice the risk of using internal investigators in such cases is always considered, but as with the point above relating to external reporting to relevant authorities, it is important to embed this consideration into procedural documents.

Historic casework

Several recommendations were made by Ineqe to address legacy failings by reviewing specific historic cases to identify gaps and ensure retrospective action where necessary. As part of this legacy work, Oxfam engaged with the appropriate Oxfam Affiliate or Partner to ascertain whether historic cases identified and shared with the Ineqe Review, had been reported to the police or other relevant agencies within their territorial areas of responsibility. The GCPS Review Team established that none of the identified 7 cases were reported to the Police. It was assessed as sufficient as the cases either did not meet the threshold for external reporting, were unsubstantiated and/or the survivors had not wanted to make a report due to concerns about safety.

As a result of matters arising from the Independent Commission Report ^{[footnote 18]}, Oxfam made a commitment to rapidly assess all allegations referred to them by the Commission and decide what action to take in relation to all. The GCPS Review Team established that the Global Safeguarding Team led the follow up work on this and there is documentary evidence of initial assessments, investigations where applicable and case outcomes. Moreover, Oxfam reported these cases to the Charity Commission.

Additionally, Oxfam followed up on 79 incidents listed on the historic Safeguarding Register for which no paperwork or file was made available during the Ineqe Review. The incidents crossed Safeguarding, HR, and Trading. The GCPS Review Team established that a new spreadsheet was compiled with all 79 incidents and analysed to determine where no clear outcome was recorded or where concerns were evident that cases had not historically been thoroughly dealt with. Oxfam concluded that there was no need for further action in relation to all 79 incidents. The GCPS Review Team accept that serious and sustained efforts were made to locate missing information but assessed the work as inadequate in relation to establishing whether ongoing risks exist or not.

Further legacy work included conducting a full risk assessment of 31 international unreported cases and sharing all partial and complete Subject of Complaint (SOC) identities relating to potential crimes that were unreported to the police in the area where the alleged crime was committed. Oxfam shared case summary information with the relevant law enforcement agency and on their advice, none of the cases were reported. The GCPS Review Team found, however, that the merit of each case was assessed on summary information.

Failing to robustly review the case files has left the GCPS Review with uncertainty about potential gaps in critical information. This finding has been accepted by Oxfam which has committed to conduct a comprehensive case review of the 31 international cases to address this potential gap.

Oxfam also shared case information of 11 UK cases with an external legal firm ^{[footnote 19]} to assess if potential crimes had been committed. Complete case files existed for the UK cases. The legal firm reviewed the files and advised that four out of the 11 cases should be reported to the police and reported them on behalf of Oxfam. The other cases were not reported either because of a lack of information or lack of consent from victims to report.

Reporting to the police and other relevant agencies

It is important to note that Ineqe found a number of Oxfam unreported cases at the time of their review. This was determined to be for several reasons including uncertainty as to whether alleged misconduct amounted to a crime in a particular jurisdiction, victims either not wishing to pursue the case or make a report to the police, and/or credible concerns that reporting might impact on the safety of a victim.

The Safeguarding Case Management SOP and accompanying tools now provide essential guidance on external reporting. The GCPS Review Team accept that Oxfam has taken steps and significantly improved in this critical practice area.

Serious Incident Reporting to the Charity Commission

Oxfam achieved full attainment for 4 of the recommendations. For the remaining recommendations there is 1 exception and 2 where gaps were identified.

Defined process

Oxfam has engaged in dialogue with the Charity Commission to refine and agree a defined process to strengthen its compliance with safeguarding SIR reporting to the Charity Commission. This has resulted in the development of a Reporting Misconduct and Serious Incident Reporting SOP adopted by Oxfam’s Trustees (Council) in July 2020 setting out how Oxfam will fulfil its obligation to report serious incidents to the Charity Commission.

To assess effective implementation of the process, the GCPS Review Team reviewed a dip sample of case files from June 2019 to March 2020. From this review it was determined that not all cases that met the threshold for SIR had been identified and reported, indicating that awareness and compliance with the defined process is still inconsistent. Oxfam accepts this finding and will report the relevant cases to the Charity Commission.

Leadership in the context of governance

There are provisions within the Terms of Reference for the Safeguarding and Ethics Committee (sub-committee of the Council) that enable direct reporting from the Global Director of Safeguarding to the Chair and Lead Trustee. Moreover, serious incidents are also discussed at full Council quarterly.

As part of a commitment to continuous improvement, Oxfam has been engaged in ongoing dialogue with the Charity Commission to ensure its fulfilment of reporting requirements. Oxfam is centralising all regulatory reporting within a specialised team, The Integrity and Intelligence Team, which sits within the Integrity and Ethics Division.

Legacy reporting

The GCPS Review team assessed reporting requirements in relation to historic cases. This correlates to the 11 UK and 31 international legacy cases covered in the case management thematic area. Additionally, the GCPS Review Team evaluated if any of the incidents with missing files met SIR criteria and were reported to the Charity Commission. This relates to the legacy work Oxfam committed to revisit on the Safeguarding Register by examining each of the entries for which no paperwork or file existed at the time of the Ineqe Review.

As set out above, Oxfam commissioned a legal firm to review the 11 UK cases for suspected crimes. The legal firm reported appropriate cases on behalf of Oxfam. Additionally, relevant cases were referred to the Local Authority Designated Officer (LADO).

Oxfam likewise sought external advice from the relevant law enforcement agency on whether any of the 31 international cases should be referred to the police/relevant agency in retrospect. No cases were reported to the police and it remains uncertain if any cases were reported to another relevant agency. As previously stated, the GCPS Review team had misgivings about the quality of the case information made available to law enforcement. Failure to robustly review the case files has left the GCPS Review Team with uncertainty about potential gaps in critical information.

Oxfam notified the Charity Commission of the outcomes of this legacy work. This was done as part of ongoing dialogue between Oxfam and the Charity Commission and through the course of the GCPS Review. Separate SIRs were not submitted.

The area of exception in this sub-topic relates to the recommendation to file SIRs for the 79 incidents with missing paperwork or files that meet Charity Commission criteria. As indicated in the ‘case management’ thematic area, Oxfam concluded that there was no need for further action for any of the incidents. The GCPS Review Team formed the view that the work carried out to establish whether ongoing risks exist or not for these incidents was inadequate. It was also not possible to determine if all cases that met SIR criteria were reported to the Charity Commission.

The GCPS Review Team established that some of the incidents had been reported to the Charity Commission. This is because all incidents on the Safeguarding Register pre-April 2017 were reported. However, at the point that the review concluded, it was not possible to determine what SIR reports remain outstanding. Furthermore, during the final fact-finding exercise, Oxfam informed the GCPS Review team that there are 7 Trading cases that require SIRs.

Oxfam has accepted this finding and committed to do whatever the Commission deems necessary to report the SIRs to provide sufficient assurance.

Governance and accountability

The finding of the review team is that Governance and accountability is an area of high attainment for Oxfam with six out of seven recommendations fully met.

In general, Oxfam, through its oversight of safeguarding, has sufficient accountability arrangements in place to prevent and address the abuse of power. Feminist principles and values alongside a zero tolerance of SEAH underpin its safeguarding approach.

While the Ineqe Review proposed an operational model for Oxfam that included setting up an Independent Safeguarding Committee (ISC) with an external chair, it is a finding of the GCPS Review based on significant evidence, that the leadership and composition of this entity has generated considerable thoughtful discussion and review. To address this recommendation, the Trustee Safeguarding Group which largely held safeguarding oversight at the time of the Ineqe Review, and which was approved in March 2018, has now been replaced by the Safeguarding and Ethics Committee. A ‘hybrid’ governance model of the proposed ISC, with a Lead Safeguarding Trustee as Chair, and with independence maintained through the ‘expressly stated’ provision for the Chair to escalate concerns directly to the Charity Commission, has been adopted. Furthermore, a senior ex-Chief Crown Prosecutor with experience in the legal areas of child sexual exploitation and violence against women is an independent member. Plans are also in place to further ensure independence through the recruitment of an additional external member from the Global South.

From Oxfam’s Trading arm, this review has seen evidence that the Lead Trading Trustee has been provided with quarterly reports formally shared with the Trustee Audit and Finance Group, although there has been some delay for Q4 19/20 due to the COVID-19 pandemic. All reports capture information regarding volunteer workers risk assessments which at the time of the previous independent review presented a specific area of concern.

To date, Oxfam has commissioned three safeguarding case audits, conducted by external auditors Girling Hughes ^{[footnote 20]} referred to above. Oxfam has committed to continuing this process in every future financial year, including a bi-annual report from the Global Director of Safeguarding to Council. GCPS has seen evidence of minutes that confirm audit discussions have taken place, although a formal safeguarding report delivered to the Trustee Safeguarding Group (TSG) as recommended, that identifies ‘trends, themes and patterns’ remains a gap.

Question 6

Explanation of scoring system and scores for thematic areas

Accepted Answer

Rating	Attainment	Assessing Adequacy of Actions	Evaluations Considerations
0	Not Met	No evidence	No evidence or evidence does not indicate the recommended has been addressed in any way.
1	Part Met	Some evidence	Some evidence that an attempt or some effort has been made to address the recommendation, but the action does not go far enough or is inadequate to a large degree.
2	Largely Met	Evidence of serious/sustained effort	evidence that serious/sustained efforts have been made to address the recommendation, but there is still some gap/remaining action required or the action taken does not go far enough or is inadequate to some degree.
3	Met	Fully met	Evidence of adequate actions to meet the recommendation in full.

Question 7

Strategy and planning actions

Accepted Answer

Recommendation 28

Action

That the 2018-2021 safeguarding strategy should be amended to include the following:

the development of a safeguarding training strategy
the development of consistent course content adapted to country context
the development of a comprehensive training programme
the development of an evaluation framework to determine impact

Score

Score: 2

Recommendation 29

Action

Building on the recently agreed Safeguarding Strategy 2018-21, Oxfam GB should produce one single safeguarding business plan to consolidate all areas of safeguarding work:

the Plan should be SMART with all actions being Specific, Measurable, Achievable, Realistic and Timely
this plan will be monitored by the Trustee Safeguarding Group (TSG)/Safeguarding Committee. Progress will be reported to the Council bi-annually

Score

Score: 3

Recommendation 30

Recommendation 1 (Action plan C)

Action

We will develop and adopt a standards-based maturity model for Oxfam’s safeguarding work - so that we work continuously to achieve safeguarding excellence.

This model will build and apply a first level set of Oxfam standards and will incorporate a refreshed Oxfam GB Safeguarding Strategy to 2021. These standards will guide Oxfam GB on how to embed safeguarding and ethical behaviour, contribute towards our target culture of zero-tolerance and better support survivors to recover and rebuild their lives. The model will drive longer-term change, by helping Trustees and Leadership Team identify strengths and areas for development over a series of “levels” of work to further enhance the safeguarding approach.

Score

Score: 3

Question 8

Systems and procedures actions

Accepted Answer

Recommendation 36 (Action plan A)

Action

Oxfam GB should update its policies as set out in these recommendations and the main body of the report. The Charity will need to develop a clear plan to ensure their development and implementation. (Link for analysis with Strategy and Planning).

Score

Score: 3

Recommendation 37

Action

Oxfam GB should revise its Safeguarding Children Policy as follows:

For all staff:

The narrative in respect of what staff or volunteers should do if they are worried about a child or concerned about a professional or volunteer working with children should be strengthened, with these sections being brought closer to the start of the document.

Ensure clear contact details are included, through which further advice can be sought.

Additional changes for staff based in the UK:

More explicit reference should be made to the CEO and Chair of Trustees retaining the overarching accountability for child safeguarding in Oxfam GB.

Strengthen relevant reference to legislation and statutory guidance.

Score

Score: 3

Recommendation 38

Action

Oxfam GB should strengthen its Safeguarding Adults policy to realise their aim to achieve a globally applicable policy, which is relevant to the confederation.

For all staff:

Definitions should be strengthened with references to extremism, modern day slavery and abuse as a result of faith, belief, and harmful practices.

Guidance on how to raise a complaint or concern should be strengthened in terms of more detail to guide staff and volunteers about what they should do if they are worried about either abuse or a professional or volunteer working with a vulnerable adult.

In the section relating to adults at risk as volunteers, further detail should be set out explaining the context of such volunteering e.g., where this might take place and in what context, would be helpful.

Additional changes for staff based in the UK:

More explicit reference should be made to the CEO and Chair of Trustees retaining the overarching accountability for adult safeguarding in Oxfam GB.

Ensure appropriate links to the Local Government Association and the Association of Directors of Adults Services guidance on dealing with adult safeguarding and domestic abuse.

Highlighting the legislation and guidance relevant to the safeguarding of vulnerable adults using information readily available via Oxfordshire’s Safeguarding Adults Board website.

Score

Score: 3

Recommendation 39 (Action plan A)

Action

That Oxfam GB’s Code of Conduct be revised as follows:

The code should state that the listed examples of behaviour are not exhaustive but aim to help employees understand the ground-rules that they are expected to observe.

Oxfam GB should strengthen the Anti-Bullying and Harassment Policy to include reference to the potential criminal and civil consequences of harassment. The procedure set out within this policy should be amended to include specific consideration as to the engagement of relevant authorities where a criminal offence may have been committed.

Score

Score: 3

Recommendation 46

Action

Oxfam GB’s interpretation of the requirements for reporting safeguarding cases to statutory authorities as set out in its PSEA Policy, currently includes the following definition of those circumstances where such reporting should take place:

‘If someone’s life is in danger or the matter relates in any way to a child or adult at risk.’

This should be broadened to include circumstances that ‘indicate a potential risk of harm to an individual or others in the future’.

Score

Score: 2

Question 9

Risk management actions

Accepted Answer

Question 10

Recruitment, vetting and performance management actions

Accepted Answer

a definition within each job description of the nature of supervision a post-holder will receive
the requirement for a new DBS check at enhanced level for every new member of staff who works directly with, or has regular contact with, children or vulnerable adults in the UK (consistent with DBS guidance and / or relevant law)
the requirement for local checks for every new member of staff who works directly with or has regular contact with beneficiaries (both children and adults) in overseas operations
the requirement to conduct repeat checks every 3 years on every member of staff who works directly with, or has regular contact with, children and young people
the requirement to take up a minimum of 2 references, one of which should be from the most recent employer
a requirement to ensure that every employer/manager involved in the interviewing process receives and can evidence that they have received appropriate training that addresses safer recruitment and refreshes this whenever the law in this context changes

Such policy should include advice and information about appropriate pathways for reporting.

Actions

We will do even more in our adoption of ‘safer recruitment’ practices – our goal is to screen out people who do not share our values.

Score

Score: 3

Question 11

Increased capability and capacity thematic area actions

Accepted Answer

Recommendation 17

Action

That Trustees, the Oxfam GB leadership team, and all senior managers (as appropriate) should, as a priority, where possible, receive accredited safeguarding training that ensures clarity on the following:

Oxfam GB’s responsibilities to children and vulnerable adults in the context of its operations in the UK. Oxfam GB’s responsibilities in the context of its safeguarding functions to overseas beneficiaries. It is acknowledged that accredited training in this regard may be harder to access. The National Crime Agency (NCA) may be able to facilitate such.

In the absence of accredited training for overseas responsibilities Oxfam GB should consider commissioning the development of such training based on its own training needs analysis.

Score

Score: 2

Recommendation 18

Action

Recommendation 31

Action

Oxfam GB should review and revise the operational parameters for the Global Safeguarding Team to ensure its functions are focused, manageable and include the following:

leadership of Oxfam GB’s engagement with relevant safeguarding structures locally, nationally, and/or internationally as required
acting as a single point of contact to provide specialist advice on specific safeguarding issues and direct investigation support to Regional Designated Officers (RDOs), for whom the manager of the Global Safeguarding Team will be responsible.
acting as the conduit through which referrals to statutory bodies are made in a timely way
providing and delivering safeguarding training
raising awareness through regular communications
quality assuring the effectiveness of Oxfam GB’s safeguarding response through a defined learning and improvement framework that includes performance information, auditing, reviews, staff, and public engagement
reporting on progress to internal and external bodies as relevant
taking responsibility for identifying escalating relevant risks to the leadership team / governing bodies

consider renaming Safeguarding Focal Points (SFP) as Designated Safeguarding Leads (DSL)
review and amend the DSL (SFP) job description – removing the prescription of a percentage of time being allocated to safeguarding and setting out the expected deliverables in respect of training, casework, advice, and guidance
appoint Deputy DSLs that can provide appropriate expertise and cover in the absence of the DSL
ensure all DSL’s receive mandatory safeguarding training (Level 3) to enable them to effectively discharge their duties

Oxfam GB should develop a defined programme of safeguarding training that is scheduled for each year. This will support those professionals involved in the delivery of training and ensure that training is planned for in a systematic way that maximises attendance. This programme should be published in advance on an annual basis with other learning opportunities included as they arise.

Trustees and the leadership team should attend the accredited day session safeguarding training mandated for other managers within Oxfam GB.

Score

Score: 2

Recommendation 78 (Action plan A)

Action

In order to maintain clear oversight on training delivery across its international and UK workforce, Oxfam GB’S learning management system should be developed to provide specific prompts for refresher training.

Score

Score: 1

Recommendation 79 (Action plan A)

Action

In order to maintain a robust overview of safeguarding training, Oxfam GB should develop and implement a training evaluation framework that captures information and involves analysis in the following related areas:

detailed qualitative data on training sessions delivered and number if attendees
the relevance, currency, and accuracy of course content
the quality of training delivery
the impact of training on safeguarding practice and outcomes for vulnerable people
to oversee and coordinate safeguarding training delivery, OXFAM GB should consider a dedicated resource to manage this activity

Score

Score: 2

Recommendation 1 (Action plan B)

Action

Score

Score: 3

Question 12

Case management thematic area actions

Accepted Answer

Recommendation 8

Action

In respect of relevant unreported cases and future cases where the safety of the victim or other issues linked to potential Human Rights violations are considered to exist, a full risk assessment should be completed. As a minimum it should address the following:

Synopsis of case (including a timeline).

evidence base for concerns
consultation feedback from appropriate police service representative or other appropriate agency (to include minutes of meetings)
relevant legal framework (and legal opinion where sought)
risk Assessment re the victim/s, potential future victims, beneficiaries, staff, volunteers, and the organisation
recommendations
detailed approval. (Whilst the recommendation may be made by the Country Director, the final decision should be agreed and authorised by the Director of Safeguarding (or equivalent) and reported to the Chair of Safeguarding Committee
such reports should be shared with the Charity Commission

Score

Score: 2

Recommendation 9

Action

Oxfam GB should engage with the appropriate Oxfam Affiliate or Partner to ascertain whether the known cases identified and shared with the Review, have been reported to the police or other relevant agencies within their territorial areas of responsibility.

Score

Score: 3

Recommendation 10

Action

Oxfam GB should support its decision making by developing a template (checklist) and contemporaneous record of their decision-making process. At a minimum this should include:

synopsis of case (timeline)
evidence base for concerns
consultation feedback from police service representative or other appropriate agency
relevant legal framework (and legal opinion where sought)
risk assessment re the victim/s, potential future victims, beneficiaries, staff, volunteers, and the organisation
recommendations
detailed approval. Whilst the recommendation may be made by the Country Director, the final decision should be agreed and authorised by the Director of Safeguarding (or equivalent) and reported to the Chair of Safeguarding Committee.
such reports should be shared with the Charity Commission if requested

Score

Score: 2

Recommendation 13 (Action plan A)

Recommendation 50

Action

In all cases where a SoC or witness is being interviewed in a language other than their native tongue or a language in which they are judged to be fluent, procedures should prescribe the use of an interpreter. Such interpreters should be independent from the investigation, save in those cases where the SoC or witness is fluent in the language of the investigator.

In some cases (for example in remote locations) where the only resource for interpretation is the Safeguarding Focal Point (DSL), their use should be risk assessed before any interview takes place. The rationale for their use by the person who authorises the interview, as well as the risk assessment should be recorded.

Score

Score: 3

Recommendation 51

Action

The preferred method of conducting interviews, particularly with SoCs or vulnerable witnesses should be face-to-face. If this is not possible, the decision to use phone or Skype should be recorded in the case file. (See R53 re practicality).

Score

Score: 2

Recommendation 52

Action

Operational protocols should be adapted to include a specific prompt and question regarding the use of interpreters for victims, witnesses and SoCs.

For interviewees, whose first language is different to that of the interviewer, interpreters should always be made available, save in those cases where the interviewee is fluent in the language of the investigator.

Exceptions can include when information is being urgently sought to help safeguard someone or prevent a crime, or if the investigator has established an adequate level of fluency by the interviewee. All exceptions should be authorised by the Head of Global Safeguarding, Head of HR or equivalent.

Score

Score: 3

Recommendation 53

Action

Relevant operational protocols should be adapted to include authorisation for interviews intended to be carried out by any means other than face to face. Protocols should not inhibit such an approach but require evidence of the rationale for the decision and authority to proceed. As a minimum, the following should be included: The nature of the interview / inquiry.

The status of the interviewee. Victim / Witness / SoC.

Action

We will improve our communications with people who report safeguarding allegations to us – so that they can be more confident in our people and our processes.

Score

Score: 3

Question 13

Serious incident reporting thematic area actions

Accepted Answer

Recommendation 3

Action

If further information comes to light that indicates one or more of the registered incidents (where no file was provided) meet appropriate Charity Commission SIR criteria, the case must be reported to the Charity Commission without delay.

Score

Score: 1

Recommendation 4

Action

Oxfam GB should implement a defined process to strengthen its compliance with safeguarding SIR reporting to the Charity Commission. This process should provide:

clarity about how and when cases should be escalated to senior managers in Oxfam GB for immediate decisions to be taken on SIR reporting
direction that Oxfam GB should undertake to report particularly serious or significant incidents immediately, with quarterly reporting for other cases
a defined frequency of reporting of SIR activity to Oxfam GB trustees (including an analysis of trends, themes, and patterns) to strengthen their oversight on these highly significant cases

make accurate decisions as to whether the incidents have been properly investigated
report to the Charity Commission and
discharge their other duties and responsibilities

Score

Score: 3

Question 14

Governance and accountability thematic area actions

Accepted Answer

Not Applicable – two recommendations were agreed by Oxfam and the Charity Commission to be not applicable as Oxfam did not have the authority to make the changes required. Consequently, these were not scored, although satisfactory responses were made by Oxfam to both of these recommendations. ↩
As noted above, two recommendations were agreed by Oxfam and the Charity Commission to be not applicable and so were not scored. ↩
Ineqe, Oxfam GB Independent Safeguarding Review, 2018 ↩
INEQE Oxfam GB Independent Safeguarding Review, 2018 ↩
The phrase ‘at the time of this Review’ both here and in subsequent parts of the report, refers to as of July 31 2020, the point at which review of evidence was completed. ↩
It should be noted that since the review arrived at this assessment, COVID-19 has impacted Trading Arm’s internal audit capacity and to that extent Trading’s safeguarding assurance arrangements have been affected by the current disruption. ↩
Independent Commission on Sexual Misconduct, Accountability and Culture, Committing to Change, Protecting People: Toward a more accountable Oxfam, June 2019 ↩
Oxfam GB Referencing Framework Guidelines, June 2019 ↩
The authorities covering criminal record checks in the UK are the Disclosure and Barring Service (DBS), covering England and Wales, Disclosure Scotland (DS) and Access NI (Northern Ireland). ↩
Oxfam GB Recruitment Policy ↩
misconduct-disclosure-scheme ↩
Recommendation 69 in the Ineqe, Oxfam GB Independent Safeguarding Review, 2018 ↩
ICPC ↩
Ineqe, Oxfam GB Independent Safeguarding Review, 2018 ↩
Oxfam GB’s Gender Pay Gap Report, April 2020 ↩
Ineqe, Oxfam GB Independent Safeguarding Review, 2018 ↩
Girling Hughes Associates, April 2020, Phase 3 Report, Oxfam GB ↩
Independent Commission on Sexual Misconduct, Accountability and Culture, Committing to Change, Protecting People: Toward a more accountable Oxfam, June 2019 ↩
Hickman & Rose ↩
Girling Hughes Associates, April 2020, Phase 3 Report, Oxfam GB ↩

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Acknowledgements

Background and overview

Scope

Methodology and explanation of scoring system

Executive Summary (summary findings by thematic area)

Strategy and planning

Systems and procedures

Risk management

Recruitment, vetting and performance management

Recruitment and vetting

Oxfam GB Shops

Culture and performance management

Increased capability and capacity

Capability

Capacity

Case management

Case management procedure and practice

Investigations

Historic casework

Reporting to the police and other relevant agencies

Serious Incident Reporting to the Charity Commission

Defined process

Leadership in the context of governance

Legacy reporting

Governance and accountability

Explanation of scoring system and scores for thematic areas

Strategy and planning actions

Recommendation 28

Action

Score

Recommendation 29

Action

Score

Recommendation 30

Action

Score

Recommendation 48

Action

Score

Recommendation 65

Action

Score

Recommendation 1 (Action plan C)

Action

Score

Systems and procedures actions

Recommendation 36 (Action plan A)

Action

Score

Recommendation 37

Action

Score

Recommendation 38

Action

Score

Recommendation 39 (Action plan A)

Action

Score

Recommendation 40 (Action plan A)

Action

Score

Recommendation 41

Action

Score

Recommendation 42

Score

Recommendation 46

Action

Score

Risk management actions

Recommendation 2 (Action plan B)

Action

Score

Recommendation 6 (Action plan B)

Action

Score

Recommendation 8

Action