Corporate report

FCDO response to ICAI recommendations on the UK’s approach to safeguarding in the humanitarian sector

Published 7 April 2022

This was published under the 2019 to 2022 Johnson Conservative government

The UK Government welcomes the Independent Commission for Aid Impact’s (ICAI) review of the UK’s approach to safeguarding in the humanitarian sector. We thank ICAI for their report and all who contributed to it.

The UK Government has tackled head-on the challenge of sexual exploitation, abuse and harassment (SEAH) in the international aid sector for many years. We will continue to prioritise safeguarding against SEAH in our work, including in our humanitarian support across the world.

ICAI’s report recognises the Government’s strong commitment to and investment in safeguarding. The report also flags the appropriateness of FCDO’s strategy, our instrumental global leadership and our multiple positive contributions which have helped to raise awareness of the issue, increase and improve reporting mechanisms and encourage cultural change in the humanitarian sector. We strongly believe that these contributions have reduced and continue to reduce the risk of SEAH.

Aspects of ICAI’s report understate the progress that has been made and give an unduly negative impression about elements of the work. We agree nevertheless that sustained effort is needed to tackle SEAH and that FCDO can strengthen our approach. We will continue to learn and to make improvements. Many challenges that ICAI raise require action across the sector and we will look to use our leadership role accordingly. Our response to ICAI’s specific recommendations is as follows:

Recommendation 1

FCDO should focus greater attention on humanitarian responses in country, supporting partners in implementing approaches to protection from sexual exploitation and abuse that are tailored to each context.

Response: partially accept

FCDO already pays close attention to humanitarian responses in country and to ensuring that an effective and tailored approach to preventing and responding to SEAH is part of those responses. ICAI’s report provides multiple examples. We will continue to do that and to share best practice across countries we work in and beyond.

Since 2018 FCDO has consistently and publicly encouraged partners to request funding for safeguarding and there are many examples of FCDO responding positively to requests. Our £10m investment in the Safeguarding Resource and Support Hub includes eight national hubs in Africa, the Middle East and Asia to support local implementing partners to provide context-specific safeguarding. All of the hubs are in countries with humanitarian responses. Our funding to the Humanitarian Quality Assurance Initiative Facilitation Fund and the Safeguarding Investigation Qualification Training Scheme also help local organisations to strengthen their safeguarding work.

ICAI’s report explains that this recommendation is rooted in a view that FCDO’s approach is ‘top-down’ and has therefore hindered change at country level. We saw no evidence for the latter in ICAI’s report and will continue to drive change both at the global level and the country level.

Recommendation 2

FCDO should ensure that trusted mechanisms systematically capture the voices of affected populations, victims, and survivors to inform policy and improve operations on sexual exploitation and abuse in humanitarian settings.

Response: partially accept

FCDO internal guidance highlights the importance of consulting with affected people as programmes are designed and implemented. The voices of victims and survivors inform FCDO safeguarding policy and programmes. The minimum safeguarding standards we require of partners place a strong emphasis on raising awareness of SEAH among affected populations, including their rights and the mechanisms available to raise concerns. We will also continue to fund initiatives to give victims and survivors more confidence to raise concerns and ways to do so.

We dispute the problem statement behind this recommendation, namely that there is an absence of systems for ensuring that learnings from consultations with affected people inform FCDO’s strategy and response. ICAI’s own report describes FCDO’s systems, such as the FCDO Safeguarding Champions Network. We welcome ICAI’s recognition of increased work to encourage the reporting of cases and that FCDO, other donors and the United Nations have all seen big increases in reporting since 2018. We agree that more can be done to ensure more people feel safe to report incidents and are exploring how to work with survivors even more systematically.

Gaining access to, and participation from, affected populations and victims/survivors of SEAH during crises is not always possible and not something that we can always ensure our implementing partners systematically achieve.

Recommendation 3

FCDO should develop and implement a research agenda on protection against sexual exploitation and abuse that identifies and prioritises key evidence gaps, in particular on what is happening on the ground.

Response: partially accept

FCDO agrees that evidence on SEAH must inform safeguarding work. We also agree that there are gaps in the global evidence base, ranging from understanding of SEAH prevalence (due to significant socio-cultural barriers to reporting in many countries), to understanding of what is most effective in tackling SEAH.

To address these issues, we are investing in various initiatives. These include a data harmonisation project to align donor reporting requirements and improve data collection and data sharing on SEAH. The Safeguarding Resource and Support Hub has a specific function in brokering evidence and highlighting gaps. It also convenes a Community of Practice that frequently debates the evidence challenges.

We do not think that a standalone new research programme specifically on SEA in humanitarian settings would deliver best value for money, given the breadth of forms of violence that communities, and especially women and girls, face. We plan instead to ensure that our research includes a strong focus on assessing the prevalence of, and preventing and responding to sexual violence (by a range of perpetrators), including the evaluation of promising initiatives, for example in existing research programmes Building an Evidence Base on Humanitarian Protection of People Affected by Conflict and What Works to Prevent Violence: Impact at Scale.

Recommendation 4

FCDO should ensure that efforts to prevent the re-hiring of perpetrators of sexual exploitation and abuse include staff recruited in countries of humanitarian response, who make up the majority of humanitarian aid workers.

Response: accept

The UK Government is committed to ensuring that all perpetrators of SEAH, whether they are recruited internationally or in the countries of humanitarian crises, are prevented from working in the aid sector. We agree that the employment initiatives which FCDO supports should include staff recruited in country.

Contrary to what the ICAI report suggests, the Misconduct Disclosure Scheme is already able to screen staff recruited in country and we will continue to encourage its use for screening all staff working in the aid sector. Since 2019 at least 29,000 checks have been made under the Misconduct Disclosure Scheme and over 140 potential new hires rejected. Project Soteria is also covering both internationally and nationally recruited staff. The Aid Worker Registration Scheme currently in its development phase is also intended to be used by both internationally and nationally recruited staff.

Recommendation 5

FCDO should conduct a review of its approach to investigating allegations of sexual exploitation and abuse by humanitarian workers in order to address the points identified by this review.

Response: partially accept

We disagree with ICAI’s finding that the design of the case management system is not sufficiently targeted to be effective. The design of FCDO’s case management system has always allowed high risk cases to be identified and prioritised. We prioritise cases of sexual exploitation or abuse involving victims and survivors who are most vulnerable, including recipients of humanitarian aid. We do not agree that FCDO guidance fails adequately to address human resource shortcomings in disciplinary actions, due process, and the rights of alleged perpetrators, whistle-blowers, and witnesses. FCDO has robust systems and guidance to ensure the confidential handling of whistleblowing and other complaints and to protect and support all those involved in the investigation process.

We also disagree with ICAI’s problem statement that some cases of misconduct between partner staff members have been inappropriately assigned to FCDO programme teams and the Safeguarding Investigations Team. Some of these cases involve partner staff members from affected populations - a group that FCDO and ICAI recognise may be particularly vulnerable. FCDO determine the appropriate investigatory response based on a range of risk factors. The risk assessments are kept under review throughout the life cycle of each case and cases are re-prioritised in line with the level of risk.

There will always be areas for improvement in our approach and FCDO is committed to continuously reviewing our case management approach and learning from every case. We will reflect on the points raised in ICAI’s report as part of a current review of our processes.