The World Humanitarian Summit: priorities for reform Contents

3Reforming the system

Institutional and funding reforms

Humanitarian and development assistance

36.The gap between the activities of short term humanitarian and longer term development actors has long been considered a problem, and has already been recognised as a priority for action at the WHS.51 Crises have become increasingly protracted over recent decades.52 As former Secretary of State for International Development Clare Short told us: “there is a need to get a better interface between humanitarian aid and development because some of the crises are so prolonged.”53 Crucially, this will involve incorporating a broad range of actors into the system. As ODI stated in written evidence: “The WHS needs to be a conversation driven by humanitarian values, but not a conversation only amongst humanitarian actors.”54 This means recognising and incorporating what the International Committee of the Red Cross (ICRC) calls the “diverse ecology of humanitarian response”.55

37.Immediate humanitarian assistance is key in supporting displaced people, but due consideration must also be given to meeting development needs in the longer term. Often, humanitarian actors find themselves required to meet these needs which can overstretch them beyond both their budgets and remits. As the ICRC stated in written evidence:

“Even though people’s needs in protracted conflict are long-term and dependent on the continuity of development infrastructure and basic services, development institutions are often absent. The result is that humanitarian organisations like the ICRC are left to sustain vital indispensable assets on short-term humanitarian budgets.”56

38.In addition to greater collaboration between humanitarian and development actors, there is a need for actors to be flexible and responsive, and to rapidly scale up programmes in response to sudden onset crises. As Development Initiatives stated in written evidence: “The flexibility to shift gears between humanitarian and development funding in response to the changing needs of affected populations is also important.”57 The US Agency for International Development (USAID) is at the forefront of flexible approaches to protracted crises, for example through the introduction of ‘crisis modifiers’—immediately available contingency funds—in the Horn of Africa after the 2011 food crisis. Having such features built into development programming allows for projects to switch into emergency mode in response to a sudden shock or deterioration in resilience that might affect a vulnerable population’s capacity to cope—an approach DFID has also experimented with in Yemen.58

39.Evidence to our inquiry suggested that failure to address predictable development issues exacerbates humanitarian need. George Graham, Head of Conflict and Humanitarian Policy and Advocacy, Save the Children UK, used the El Niño weather event as an example of this. He told us that:

“Right now, we are seeing an entirely predictable El Niño event with entirely predictable consequences on food and security. One million children in southern and eastern Africa are severely and acutely malnourished. It is completely unnecessary. It is a scandal that that has happened, is happening again and keeps happening. It should not fall into the humanitarian basket to deal with that, because that is really clearly a failure of development.”59

If crises are occurring in the first place due to a failure of development programmes to adequately prepare and build the resilience of vulnerable populations, the responsibility of development actors should be recognised.

40.One development policy area where humanitarian and development interventions could be better connected is education. Crises often have a significant impact on access to schooling, particularly for girls. A girl in South Sudan is more likely to die in childbirth than complete secondary school and in Somalia, fewer than 2% of girls enrol in secondary school—both countries with protracted crises.60 Surveys in crisis-prone countries consistently show that education is a top priority for affected populations.61 This should be recognised at the WHS, in keeping with the message of a greater voice for the people. In written evidence, Africa Educational Trust refers to education as the “bridge between humanitarian assistance and long term development work” as it enables people to live “healthy, meaningful and resilient lives”.62

41.However, in 2013, development assistance for primary education in low and low-middle income countries averaged $15 per child—in countries in protracted crises it was only $7 per child.63 In keeping with the UK Government’s commitment to fragile states, finding the right approach to investing in the education of children affected by crises is crucial. The World Humanitarian Summit will host a special session on ‘Education in Emergencies and Protracted Crises’, which will see the launch of the Education Crisis Platform. This platform will aim to provide faster and flexible support where it is most needed.

42.Closing the gap between the activities of short term humanitarian and longer term development actors has been recognised as a priority for action at the World Humanitarian Summit. While prior discussions on this topic have failed to deliver much needed reforms, the Summit is an important opportunity to launch a concrete set of actions to deliver results.

43.DFID should propose a number of ways to close the gap between development and humanitarian interventions. It should:

44.We commend DFID’s commitment to education in crises, particularly its support for the No Lost Generation Initiative. Education is consistently highlighted as a priority for those affected by crises and acts as a bridge between overcoming crises in the short term and longer term development.

45.DFID should use the Summit to stress the long term development effects of disrupted education and press for commitments on providing an education for all children in emergencies and protracted crises. It should ensure that the Education Crisis Platform reflects a truly transformative approach to education in crises.

Independent needs assessment

46.In the humanitarian system, needs assessments are currently undertaken by the same agencies that are appealing for funds. Mukesh Kapila told us that as an organisation appealing for humanitarian funding: “you decide what the needs are, you write an appeal, you get the money, you decide how to spend it and then you judge for yourself whether or not you have been successful.”64 This is a worrying feature of the system. CAFOD says that, as a result, there is “a lack of confidence in the needs identified through the current needs assessment approaches, which are seen as inflated.”65 The incentives built into such a model also encourage agencies to expand their activities, sometimes irrespective of the relevance and their technical expertise.66

47.In their evidence, both CAFOD and Mukesh Kapila argue the need for an independent body to undertake the assessment of humanitarian needs. Mr Kapila stated that:

“This body of people must be completely separate from both the givers of the funds and the intermediaries responsible for spending them, whose only purpose is to make sure that what is done with the money is done in the best interests of the people on the ground.”67

This sentiment was echoed by respondents to the consultation process ahead of the WHS, including by crisis-affected people. The Synthesis Report states that: “a mechanism is needed to verify and improve the quality and credibility of needs assessments, track progress in meeting needs and provide a channel for handling complaints by affected people. These mechanisms should be independent, and consult local people, government authorities, civil society and humanitarian organizations.”68

48.The global humanitarian system displays a worrying lack of separation of powers between those assessing needs and those appealing for funds. DFID should propose the establishment of an independent body to be responsible for conducting needs assessments in crises. DFID should work with like-minded donors in the build up to and at the Summit to ensure this fundamental problem is addressed.

High-level coordination and structural reform

49.In evidence to this inquiry, several organisations (including ODI, Save the Children, ActionAid and DFID) called for reforms to the Inter-Agency Standing Committee (IASC). While the IASC plays an important coordinating role in bringing together key UN agencies, consortia representing largely Western NGOs and the Red Cross and Red Crescent movement, neither donors nor non-Western NGOs are represented. This has led some to question the basis of its representative capacity and governance structures. On the subject of expanded membership of the IASC, Desmond Swayne TD MP, Minister of State, DFID said: “It is important that the IASC has legitimacy. That involves inclusiveness.”69 ActionAid stated that IASC membership should be reviewed to reflect the “new reality” of humanitarian action,70 and ODI suggested that such a review should bring about an enlarged membership which includes “non-traditional” organisations.71

50.Save the Children stressed the need for: “a concerted plan at the WHS for decentralisation of decision-making, management and coordination within the international humanitarian system”.72 One example of where centralised decision-making had unintended consequences was the case of Cyclone Pam which struck Vanuatu in March 2015. George Graham told us that while Vanuatu is used to cyclones and has preparedness measures in place, the approach imposed by the IASC framework through international agencies created a “disconnect and unnecessary dysfunction” where local organisations were crowded out.73 Localisation of humanitarian responses will be a key outcome from a successful WHS, and reform of the IASC to make it less remote and deliver a more responsive and flexible framework for humanitarian action could help to deliver this.

51.However, it also should be noted that we heard a very different perspective on the IASC with two areas of caution from Mukesh Kapila. Firstly, he told us that the IASC is “not the great block to change” that some claim it is.74 In order to achieve the genuine reform that the humanitarian system needs, he went on to say: “It is not about changing institutional structures and systems; it is about changing mind-sets”.75 Institutional reforms to the IASC and other bodies should be undertaken to achieve a more representative coordinating body, but that should not be seen as a panacea for the problems in the humanitarian system. Real change requires that IASC reforms are accompanied by a change of thinking within the agencies the IASC is comprised of. Secondly, Mr Kapila warned of the dangers of an expanded IASC membership including donors and governments. He said:

“Either you are a donor giving money and holding to account those who are spending your money; or you become part of the action and the operational policy-making machinery. What you cannot do is both.”76

52.A number of organisations have called for institutional reforms to the Inter-Agency Standing Committee (IASC), the humanitarian system’s high-level coordinating body. It is our view that the IASC represents a dated approach to the coordination of humanitarian assistance that is increasingly failing to represent the reality on the ground.

53.DFID should press for expanded membership of the IASC, with an aim to include representation from local and national organisations in order to move towards a decentralised network model. The inclusion of voices from affected communities, particularly women and women’s organisations, is important. Decision-making processes within the IASC should remain independent of donors and governments who should focus on holding the institutions that govern the humanitarian system to account. Expanded membership should therefore not include donors or governments. At the High-Level Leaders’ Roundtables, the UK Government should make it clear that reforms of institutional structures are a necessary but not sufficient condition for an improved system. Rather than being content with tweaks to the way institutions are run, all actors must work together to foster a system-wide change in thinking on how humanitarian assistance can best be delivered.

54.The High-Level Panel on Humanitarian Financing points out that: “Humanitarian assistance overreaching itself is a result of a wider systems failure […] Faced with exponential growth in humanitarian needs, there is an urgent requirement to overhaul the global approach to providing aid.”77 While structural changes alone may not be sufficient to deliver this complete overhaul, we believe that the institutions within the system ought to be examined.

55.Regarding the structure of the system, a recent inquiry into DFID’s responses to crises by the House of Commons Public Accounts Committee (PAC) concluded that: “The value for money for the UK taxpayer of the Department’s funding of UN agencies is undermined by the overlapping remits of the agencies and inflexibility in their systems.”78 This would suggest that reforms are a necessity.

56.However, not all parties agree on the need for reforms, let alone on how to achieve them. The UN Under-Secretary General for Humanitarian Affairs, Stephen O’Brien, has stated that “the system is not broken. It’s simply financially broke”,79 while in evidence to the PAC inquiry, Mark Lowcock, Permanent Secretary, DFID identified three priorities in DFID’s efforts to “improve” the multilateral agencies:

“The first is getting them to work together better and compete less. We are using some of our funding to try to force that join-up. The second is about data quality. I have commissioned an independent review, which I have asked them to help and engage with, to look at all the data and information about where their costs fall so we have a much better understanding of what they spend money on and can have a proper dialogue about it. The third is that we give them multi-year funding, and we would like to pass on the benefit of that to their sub-agents.”80

Minister Swayne suggested that DFID will try to shape the system using financial incentives rather than redefining institutions. He told us that:

“The consensus in the Department is that we need to provide incentives in the form of the financing—the way that we finance the system—to get it to behave more in the way they want, rather than to secure institutional reform.”81

57.Reforms should be pursued by all available means, including examining the structure of the system itself. Heba Aly, Managing Editor of IRIN News, highlighted in written evidence that: “the problems facing the sector are much more fundamental. It has become a mammoth machinery that has, in many ways, lost track of what it stands for.” The PAC report suggests that DFID has had limited success in influencing change in UN institutions in the past. It states that: “the Department has found it difficult to influence the UN to adapt its structure and the practices of individual UN bodies to improve their effectiveness.”82 As a result, we want to ensure that the opportunity for a global push to address institutional issues is not lost at the WHS.

58.Despite the importance of reforms, the WHS appears to be lacking a forum to address the problems at the core architecture of the system. A rethinking of the humanitarian system should include a close examination of its structure. A High-Level Roundtable that was planned on “Building the future of humanitarian action: towards more effective, context-specific, and predictable responses” was dropped from the final list of events. As a result, the WHS has no high-level forum to address the concerns about the core architecture of the system.

59.We have heard evidence that there is a need for fundamental, systemic reform to address concerns about the core architecture of the humanitarian system and rethink the approach to humanitarian assistance. We are disappointed to see the lack of a forum to directly address these issues at the World Humanitarian Summit (WHS), particularly the exclusion of the High-Level Leaders’ Roundtable on “Building the future of humanitarian action: towards more effective, context-specific, and predictable responses” from the final programme.

60.We urge DFID to build consensus on the need to examine these concerns in the build-up to the WHS. An independent investigation of the organisational structures within the humanitarian system should be commissioned. Where structural problems are evident, as determined by thorough and objective consideration of the evidence, DFID should strive to find like-minded donors and push for an open conversation on how best to deal with them through the necessary reforms.

An improved funding model

61.Five countries fund nearly two thirds of global humanitarian finance provided by governments (in 2015, these were the United States, the UK, Germany, Japan and Sweden),83 while six UN agencies receive and manage half of that funding.84 The giving, receiving and channelling of funds within the system is thus concentrated among a small pool of very large actors. This is a core problem that the WHS needs to address, as written evidence from ODI stated: “This creates a ‘humanitarian oligopoly’ that both marginalises new funders and excluding new, potentially significant, sources of funding, and crowding out national and local actors who might be more efficient and effective at responding to crises.”85

62.The imbalance of donors and agencies in the system underpins the High Level Panel on Humanitarian Financing’s proposal of a “Grand Bargain”—a new model of humanitarian financing based on flexible financing by donors and more transparent and efficient delivery by agencies and other humanitarian actors. Much of the evidence to our inquiry agrees that the Grand Bargain is a positive step. George Graham of Save the Children stated that: “In particular, the work around transparency and accountability has the potential to be transformative.”86

63.A further key component of the Grand Bargain raised in evidence, related to better coordination between humanitarian and development actors, is the importance of a commitment to predictable, multi-year financing. Meeting immediate, life-saving needs is undoubtedly important, but humanitarian assistance is rarely limited to the short-term. Sustained funding is required over a long period to “respond to chronic or recurrent needs, to support recovery processes, and to build capacity and resilience to prevent or withstand further shocks.”87 However, as we heard from World Vision:

“Longer-term responses are often made up of multiple cycles of short term response. This results in more work for operational agencies, unpredictability for intended beneficiaries and inefficiency for donors.”88

Figure 2: Long-, medium- and short-term recipients of official humanitarian assistance from DAC donors, 1990−2013

Source: Development Initiatives based on OECD DAC and UN CERF data

64.Multi-year financing is important, not just to align the timescales of budgeting and needs, but also to demonstrate greater commitment and remove the element of unpredictability and volatility of funding.89 A 2013 review of development assistance in fragile states found that over half of them experienced four or more ‘aid shocks’ between 2005 and 2013: a fluctuation of 15% or more from one year to the next.90 This highlights the need for predictable funding to plan effective, long term programmes that can build resilience and help break the recurrent and chronic nature of certain crises. The benefits of multi-year financing also allow donors to make necessary longer term investments in their programmes. This is demonstrated by DFID’s work in Somalia, where investment in monitoring and evaluation has made programming more flexible, adaptive and accountable to beneficiaries.91

65.Multi-year financing is also of particular importance with regard to education in crises. SDG 4.1 stresses the need for quality primary and secondary education, and as Africa Educational Trust stated in written evidence, short term humanitarian budgets:

“typically target construction of school buildings, purchasing textbooks and teachers resources and classroom equipment, while efforts to improve quality education, such as the deployment of well-trained quality teachers, are side-lined.”92

Financing quality education in humanitarian crises requires the capacity to work in partnership with Ministries of Education to ensure well-trained teachers and relevant curricula. Such efforts cannot be as effective on traditional, short term humanitarian funding timescales.

66.Another important issue that surrounds financing for humanitarian crises is the role of the International Financial Institutions (IFIs) such as the World Bank. As was detailed in the Committee’s report on the Syrian refugee crisis,93 countries that neighbour major crises in the Middle East and elsewhere can struggle with the financial burden that hosting refugees places on them. Yet such countries often do not have the access to the long term, predictable financing that they need, such as through the World Bank’s International Development Association (IDA), due to them having incomes that are too high to meet eligibility criteria. It has also been argued that the IDA’s Crisis Response Window, the dedicated funding mechanism for responding to crises, is inadequate, with the United Nations Secretary General (UNSG) suggesting that it should be tripled.94

67.A key aim for the World Humanitarian Summit needs to be a new funding model that can deliver humanitarian assistance in a more efficient and effective manner and which seeks to broaden the donor base. We welcome DFID’s efforts in increasingly introducing multi-year financing into its programming in fragile states. In line with Sustainable Development Goal (SDG) 4.1, multi-year financing is particularly important in delivering quality universal education to children in crises.

68.DFID should push for a commitment from all donors to a reoriented funding model that invests in longer term needs through multi-year financing, particularly at the High-Level Leaders’ Roundtable on humanitarian financing. DFID should focus on education as a key sector that needs an alternative financing approach, building consensus around commitment to education in crises in conjunction with multi-year commitments.

69.DFID should also ensure that the Summit results in a reinvigorated role for the International Financial Institutions, particularly the World Bank, in responding to crises. This should involve a push to expand the World Bank’s Crisis Response Window and a discussion on how the World Bank can better support crisis-affected countries who are not eligible for support from the International Development Association (IDA). Such discussions should be linked with the upcoming IDA replenishment.

Innovative approaches to risk financing

70.At US$15 billion, the gap between humanitarian funding and humanitarian needs has never been greater.95 At the core of the financing agenda for the WHS is the idea that available resources need to be used in smarter and more efficient ways. In the UNSG’s report, he emphasises the need for the humanitarian system to shift its focus away from short term funding and towards longer term financing. He writes that:

“While grants will continue to play a central role in the aid sector, particularly in acute conflict or sudden-onset disaster situations, they will need to be complemented by a broader range of financing options, including risk-pooling and transfer tools, impact bonds, microlevies, loans and guarantees. Ultimately, shifting from funding to financing means offering the right finance tool, for the right actor, at the right time.”96

71.Many have argued that there is particular potential for a transformed approach to financing through risk transfer mechanisms such as weather-indexed microinsurance, parametric disaster (re)insurance and sovereign risk pooling facilities. The High-Level Panel on Humanitarian Financing stated that such tools would increase liquidity for early action, rather than relying on post-crisis ‘relief-itemised’ assistance.97 According to RESULTS UK, there are three core benefits in shifting towards such an approach. It would:

72.The High-Level Panel points out that there is already movement in this area. The African Risk Capacity (ARC) is an agency of the African Union, established to help the financial capacity of governments to deal with crises. While the Caribbean Catastrophe Risk Insurance Facility (CCRIF) is an established regional risk pooling facility. The Group of Seven (G7) also recently launched an initiative on climate risk insurance (InsuResilience) with the aim of increasing, by up to 400 million, the number of people in disaster-prone countries that have access to direct or indirect insurance by 2020.99 It is important that any renewed approach to financing is flexible and adaptive to the unique contexts of crisis-prone countries. As Bruno Lemarquis of UNDP stated: “we need a lot of work on the financing architecture to ensure you use the right type of funding instrument at the right moment for the right type of situation.”100

73.Social protection—protecting the poor from social risks through targeted policies to support them—can provide an indirect insurance mechanism that offers the potential to mitigate the effects of disasters and avert crises. As George Graham of Save the Children told us:

“Another thing you can do, and some countries are getting there on this, is to have social protection systems—benefit systems, if you like—that already exist but flex when there is obviously going to be a spike in humanitarian need […] That is a mechanism that DFID is championing and trying to introduce in various parts of Africa. It is something that needs more energising.”101

74.A report from the World Bank has highlighted the potential for disaster-sensitive social protection programmes in lowering the vulnerability of the population, minimising costs to governments, and preventing protracted social and economic crisis. As the report states: “By leveraging existing and already well-functioning social protection platforms, disaster-risk social protection programs can help more effectively target the most vulnerable populations and provide immediate assistance following a disaster.”102 The social protection agenda is also important in the context of the Sustainable Development Goals (SDGs), with Goal 1.3 focusing on the implementation of nationally appropriate social protection systems and measures for all.

75.A new approach to the financing of the humanitarian assistance is undoubtedly needed to close the US$15 billion gap between needs and resources. New approaches to direct and indirect insurance mechanisms should be a key feature of this agenda at the World Humanitarian Summit.

76.We urge DFID to champion risk transfer mechanisms such as climate insurance at the World Humanitarian Summit (WHS) and negotiate multi-year commitments for the G7 InsuResilience initiative up to 2020. We commend DFID’s work in advocating for the role of social protection systems in avoiding crises, and we encourage the Department to make commitments to social protection a key objective of the WHS. In order to do this, DFID should ensure that all actors in the global system have plans in place to deliver on SDG Goal 1.3 (on social protection systems), and that disaster-prone countries are assisted in achieving this goal.

Make the system truly global

77.Between May 2014 and July 2015, the WHS Secretariat launched eight regional consultations involving more than 23,000 people. Coupled with thematic and stakeholder consultations, online dialogues and the review of over 400 written submissions, the WHS agenda emerged from a broad consultation process. One of the main themes that surfaced was the concept of dignity for affected people, particularly in their ability to exercise greater voice and choice in humanitarian action. As Professor Mukesh Kapila CBE, Professor of Global Health and Humanitarian Affairs, University of Manchester, told us:

“The humanitarian system could be better designed if it started off by listening to the people […] What they are looking for is not charity; what they are looking for is dignity.”103

IRIN, an independent humanitarian news organisation, stated in written evidence that: “aid agencies have improved their ability to garner feedback from the communities they serve, but they have yet to be able to meaningfully and systematically respond to it.”104 Listening to and responding to the voices of affected communities is both a challenge and an opportunity for a reinvigorated and truly global humanitarian system.

Strengthening local actors

78.In order to make the system truly global and deliver on the concept of dignity, there is need for systemic reform that puts crisis-affected people at the centre of humanitarian action. One way of doing this is through supporting and enabling national and local actors who, as Christian Aid put it:

“Are able to shape programmes in a contextually appropriate, culturally sensitive way, based on a community’s own understanding of its needs. Local partners, closer to and more trusted by communities, are better-positioned to ensure accountability to affected populations, and respect long-term perspectives.”105

79.The primary responsibility for dealing with crises lies with domestic governments, however the capacity of national authorities to meet the needs of people in crises varies enormously. This is also true of local actors who are often the first and last responders in crisis situations and also play a critical role in preparedness, disaster risk reduction, building resilience and transitioning towards recovery.106 Partnerships with national and local actors are thus key, yet as one report highlights, “Major evaluations of numerous high profile humanitarian crises—most notably that of the Indian Ocean tsunami—have identified insufficient investment in, and commitment to, such partnerships as the biggest hindrance to effective performance.”107

80.Several recent crises have shown the value of strong local responses. As Christina Bennett of ODI told us:

“Local is most of the time faster. You saw that in the Philippines, where it was church groups who were the first to respond to Typhoon Haiyan. Local organisations can be more appropriate. During the Ebola crisis you saw that it was communities and community health workers who were able to deliver the messages about handwashing and safe burials much more effectively than anybody else. You see in Syria, and we have said before, that local populations can get better access to population when international actors are blocked.”108

81.The WHS synthesis report recommended that direct funding of local organisations be expanded.109 One way in which DFID is already leading the way is through initiatives such as the Start Fund, a UK-based NGO consortium which pools funding from its members (and donors) into a fund that members can tap into to quickly respond to rapid-onset crises. This represents an innovative approach which provides a greater proportion of funding to local and national NGOs relative to the traditional humanitarian system.110 Initial decisions about the need for crisis responses and assessments of the level of need lie with local civil society actors who are closest to affected communities. This approach ensures that responses are complementary and coherent in a way that single organisations cannot achieve individually.111 At the WHS in May, ADESO will launch a similar NGO network and pooled fund aimed at southern-based NGOs.

Box 1: The Start Network / Fund

The Start Network is an international network of NGOs that enables a broad range of humanitarian actors and partners to provide the best possible solutions for people affected by crises. It provides platforms to enable collaborative approaches to decision-making and provision in order to foster a more collaborative and decentralised approach. At present the Network is overseeing £56m of such programmes in West Africa and Europe and is investing in Network infrastructure and capability to deliver more such collaborative responses in the future.

In April 2014 the Start Network launched the Start Fund, the first multi-donor pooled fund managed exclusively by NGOs. The Start Fund disperses money within 72 hours of a crisis alert, which makes it one of the fastest early response mechanisms in the world. To date, the Start Fund has been activated in more than 40 emergencies, helping more than 3.5 million people in 28 countries. The average time from alert to project selection is 66 hours; 50% of the projects are implemented by local partners and 83% are selected in country.

Source: Start Network (DAS0033)

82.While there are major challenges in delivering on the localisation agenda, DFID can play an important part in overcoming these. There are limitations to what local organisations can achieve themselves. They may lack specialised skills and the ability to respond at scale, and in conflicts they can be seen as partial, putting them at risk.112 Markus Geisser of the ICRC gave an example of this in oral evidence:

“At times, local humanitarian actors, particularly in armed conflict, get into trouble, politically and emotionally. A clear example is today they simply cannot go into Syria, into a federal prison, to check the living conditions of detainees.”113

83.The Syrian example is one where a response from an international organisation such as the ICRC is most appropriate, and it highlights the importance of subsidiarity within the humanitarian system. ODI define subsidiarity as the principle that: “matters ought to be handled by the smallest, lowest or least centralised competent authority.”114 Crisis responses should operate on the basis of this principle so that needs are determined and responded to locally where possible, with the support of international organisations, NGOs and governments. Only in instances where local responses are not the best solution should the emphasis fall on international actors.

84.On the part of donors, there may be concerns about increasing funding to local organisations. Donors need to know that their money is being spent effectively, and there are practical challenges with overseeing a large number of small organisations. As Rt Hon Desmond Swayne MP, Minister of State for DFID, expressed: “I have to be aware of the problem of managing lots of little ones and having the due diligence to ensure that they are capable.”115 Yet the importance of the localisation agenda means that, as CAFOD urged in written evidence, DFID needs to be at the forefront of policy-thinking on how to address this problem.116 Incentivising investment in local responses can be done by stressing the potential cost savings of “short-circuiting the often lengthy chain of transactions from governments to crisis-affected populations.”117

85.In its inquiry into DFID’s management of crises, the Public Accounts Committee concludes that: “In complex projects the Department does not always know the range of organisations its first tier partners are funding, making it difficult for the Department to manage risks.”118 Greater transparency in the humanitarian system can help donors manage their risk whilst also building more trusting relationships with partners. DFID is an ‘early adopter’ of the International Aid Transparency Initiative (IATI), a voluntary scheme aimed at improving transparency by having humanitarian and development actors publish data on their activities through the IATI Standard. A stronger push amongst all donors and intermediaries to sign up to the IATI Standard would create a more transparent environment and inspire confidence in engaging with a broader range of partners.

86.DFID should expand upon its good work in incorporating local actors into crisis response in a number of ways:

An inclusive system

87.A genuinely global system needs to be more inclusive. As Age International and HelpAge International point out in written evidence:

“The Red Cross Code of Conduct states that humanitarian action must be carried out on the basis of need alone. However, the current humanitarian system is set up to deliver one-size-fits-all responses, which fail to take account of the specific needs of marginalised groups”.119

Such marginalised groups include the elderly, people with disabilities, women and children and those from minority ethnic and religious groups. Three-quarters of those who died during Hurricane Katrina in 2005 were aged over 60, and more than half of those who died during the Japanese tsunami in 2011 were aged 65 or over.120 For every Indian or Sri Lankan man killed in the 2004 Indian Ocean tsunami, four women lost their lives.121 Three quarters of people with disabilities do not have adequate access to basic assistance in crises, including water, shelter, food or healthcare.122 400 million children from minority ethnic and religious groups are being discriminated against worldwide.123

88.As UNICEF points out with regard to children, marginalised groups have unique populations with differing sets of needs, perspectives and capacities that differ from adults.124 Approaches to humanitarian action should reflect the specific needs of groups that are often marginalised: at the moment those needs are often overlooked. Approximately 15% of the global population has a disability, yet, according to Handicap International, less than 1% of international humanitarian aid is targeted at those with disabilities.125 Handicap International notes DFID’s good work in pushing the system to change in this respect. Its written evidence states that: “DFID has taken multiple steps to improve its inclusive approach to humanitarian assistance, including specifically mentioning older and disabled people as vulnerable groups in their humanitarian policy and by prioritising humanitarian assistance in DFID’s Disability Framework 2014.”126 However, more still needs to be done to encourage other actors to adopt universal standards of inclusivity in the humanitarian system.

89.ActionAid raised concerns in written evidence about the representation of women in leadership roles in the humanitarian system. Their written evidence stated:

“The current humanitarian system is male-dominated and its architecture discriminates against women from playing leadership roles even though they are often the first responders. Women are in the frontline of humanitarian responses, taking risks, providing unpaid care and essential work. But they are not sufficiently represented in key leadership and decision-making humanitarian roles.”127

Handicap International also expressed the need to: “Correct the neglect of people with disabilities in humanitarian action by recognizing their leadership and capacity to meaningfully participate in and actively contribute to the inclusion of all marginalised/at risk groups”.128

90.DFID has rightly championed the needs of vulnerable groups in crises in the past, and the World Humanitarian Summit is an opportunity to develop global standards on inclusivity in humanitarian responses. We commend DFID for its support of the Charter on Inclusion of People with Disabilities to be launched at the Summit.

91.DFID should advocate for the outcomes of the World Humanitarian Summit (WHS) to include a pledge on global standards of inclusivity in the humanitarian system from all donors and funding recipients. This should include a commitment that no group will be neglected in responses and a recognition that needs vary within crisis-affected populations. We urge DFID to ensure that strong support for the Charter on Inclusion of People with Disabilities across the international community is a key outcome of the Summit. DFID should also lead a drive to promote diverse leadership within the humanitarian system, so that the interests of vulnerable groups are reflected in processes driving decision-making and funding allocations.

Counter-terrorism legislation (CTL) and humanitarian responses

92.In February 2016, Rt Hon Andrew Mitchell MP and Rt Hon Clare Short, both former Secretaries of State for International Development, wrote to the Committee to express concerns about the ability of NGOs to operate within and close to Syria. One of these barriers, particularly relating to Muslim NGOS, pertains to counter-terrorism legislation. As they wrote:

“we have seen clear evidence that the relief effort in Syria is hampered both by fears of anti-terrorist legislation and the effect it could have on the charities themselves. Also the reluctance of banks in Britain to transfer funds on the grounds that they themselves could fall foul of this legislation.”129

Such concerns were echoed in written evidence, including by ODI and Christian Aid, with the latter saying that: “Counter-terrorism legislation is severely impeding humanitarian assistance from reaching those most in need.”130

93.At a time when the humanitarian system is stretched to its limit, the system must make effective use of all the resources and actors at its disposal. The security of international financial flows is of paramount importance in the fight against terrorism, yet counter-terrorism legislation can act as a significant impediment to humanitarian operations through limiting the access of legitimate NGOs to financial services. A report published by ODI’s Humanitarian Policy Group found that:

“British INGOs face increasing restrictions on their access to financial services relating to the global regulatory framework in place to prevent the financing of illicit activities, including terrorism […] In the worst cases, donations transferred to British INGOs and payments made by them have been delayed, blocked or returned; accounts have been frozen or closed, and requests to open new accounts have been declined.”131

Often it is the organisations that operate in countries where proscribed armed groups are present, such as Syria, Somalia, Afghanistan and Gaza, who face the greatest challenges in this respect. However, it is in these places that humanitarian needs are often greatest.132

94.We understand from Dylan Winder, Head of Humanitarian Policy and Partnerships at DFID, that the Department has established a working group with NGOs and the banking sector to try and resolve these problems. We encourage the Government to explore ways to reconcile the need to stop financial flows to terrorists with the need for NGOs to operate effectively in conflict-affected environments.

95.A further concern relates to those who work for NGOs in these environments, who not only risk their lives in such dangerous environments, but also risk falling foul of counter-terrorism legislation. This is what Rt Hon Andrew Mitchell MP referred to as the “Guantanamo Bay danger”, where, for Muslim development actors particularly, even being photographed in the same area as armed groups could mean they are seen by authorities as being associated with terrorist groups. As Mr Mitchell told us: “There is a real danger to some of these humanitarian actors that this terrorist legislation not only restricts their financing but places an added burden upon them, when they are doing dangerous and difficult work relieving people in very difficult circumstances.”133

96.It is easy to see why the UK’s counter-terrorism legislation may cause concern for humanitarian actors. Section 12 of the Terrorism Act 2000 states that “A person commits an offence if he arranges, manages or assists in arranging or managing a meeting which he knows is to be addressed by a person who belongs or professes to belong to a proscribed organisation.”134 Therefore, those required to engage with proscribed organisations to negotiate humanitarian access (including with several groups operating in Syria where access is a big problem) may be in breach of counter-terrorism laws. Other jurisdictions such as Australia and New Zealand have exemptions for humanitarian actors that are appropriate for their counter-terrorism legislation. For example, Australian law prohibits associating with a terrorist organisation, except where “the association is only for the purpose of providing aid of a humanitarian nature”.135

97.While we recognise the importance of the security of international financial flows, we are concerned that, in certain circumstances, NGOs are not able to operate effectively due to unintended adverse consequences of counter-terrorism legislation.

98.We commend DFID for taking steps to address this issue domestically, but we urge it to use the World Humanitarian Summit as a platform to address this problem at the global level. This should involve the opening of a dialogue between all parties concerned (the financial sector, NGOs, national governments, etc.) to explore solutions to these problems. We also urge the UK Government to explore reasonable exceptions in counter-terrorism statutes for humanitarian activities, as exist in jurisdictions such as Australia.


51 High-Level Panel on Humanitarian Financing Report to the Secretary-General, Too important to fail—addressing the humanitarian financing gap (January 2016) p6-7

52 UN Secretary-General, One humanity: shared responsibility, para 73

53 Q63

54 ODI (DAS0016) p3

55 International Committee of the Red Cross (DAS0028) p4

56 International Committee of the Red Cross (DAS0028) p5

57 Development Initiatives (DAS0010) para 1.2

58 Development Initiatives (DAS0010) para 4.9

59 Q84

60 Africa Educational Trust (DAS0007) para 6.1

61 Overseas Development Institute, Investment for education in emergencies: A review of evidence (February 2015) p viii

62 Africa Educational Trust (DAS0007) para 1 & 4.2

64 Q118

65 CAFOD (DAS0027) para 4.1

66 ODI (DAS0016) para 23

67 Q118

68 World Humanitarian Summit, Restoring humanity: global voices calling for action (October 2015) p xii

69 Q26

70 ActionAid (DAS0030) para 14

71 ODI (DAS0016) para 14

72 Save the Children (DAS0029) p5

73 Q107

74 Q120

75 Q126

76 Q119

77 High-Level Panel on Humanitarian Financing Report to the Secretary-General, Too important to fail—addressing the humanitarian financing gap (January 2016) p2

78 Committee of Public Accounts, Thirty-fifth Report of Session 2015–16, Department for International Development: responding to crises, HC 728, para 6

80 Oral evidence taken on 10 February 2016, HC (2015–16) 728, Q41

81 Q22

82 Committee of Public Accounts, Thirty-fifth Report of Session 2015–16, Department for International Development: responding to crises, HC 728, para 6

85 ODI (DAS0016) para 22

86 Q94

87 Development Initiatives (DAS0010) para 4.6

88 World Vision (DAS0002) para 9

89 Development Initiatives (DAS0010) para 4.2

90 Development Initiatives, Global Humanitarian Assistance Report 2015, (June 2015) p115

91 DFID (DAS0025) para 10

92 Africa Educational Trust (DAS0007) para 7.2

93 International Development Committee, First Report of Session 2015–16, Syrian refugee crisis, HC 463

94 UN Secretary-General, One humanity: shared responsibility, para 152

95 High-Level Panel on Humanitarian Financing Report to the Secretary-General, Too important to fail—addressing the humanitarian financing gap (January 2016) p v

96 UN Secretary-General, One humanity: shared responsibility, para 159

97 High-Level Panel on Humanitarian Financing Report to the Secretary-General, Too important to fail—addressing the humanitarian financing gap (January 2016) p14

98 RESULTS UK (DAS0018) para 8

99 G7 Germany, Think Ahead, Act Together (June 2015) p16

100 Q17

101 Q88

103 Q116

104 Heba Aly, IRIN News (DAS0032) para 11

105 Christian Aid (DAS0019) para 3.3

106 World Humanitarian Summit, Restoring humanity: global voices calling for action (October 2015) p14

108 Q18

109 World Humanitarian Summit, Restoring humanity: global voices calling for action (October 2015) p xiii

110 Direct funding of local and national NGOs accounted for only 0.2% of all funding reported to the UN Office for the Coordination of Humanitarian Affairs (OCHA) Financial Tracking Service (FTS) in 2014, while 50% of the Start Fund’s projects are implemented by local partners.

111 Start Network (DAS0033) p1

112 Q18

113 Q18

114 ODI (DAS0016) p3

115 Q27

116 CAFOD (DAS0027) para 3.4

117 Development Initiatives (DAS0010) para 4.12

118 Committee of Public Accounts, Thirty-fifth Report of Session 2015–16, Department for International Development: responding to crises, HC 728, para 7

119 Age International and HelpAge International (DAS0014) para 13

120 Age International and HelpAge International (DAS0014) para 4

122 Handicap International UK (DAS0013) para 3

123 Save the Children Every Last Child (April 2016) p vi

124 UNICEF (DAS0011) para 1.2

125 Handicap International UK (DAS0013) para 8

126 Handicap International UK (DAS0013) para 15

127 ActionAid (DAS0030) para 19

128 Handicap International (DAS0013) para 28

129 Rt Hon Andrew Mitchell MP and Rt Hon Clare Short (DAS0031)

130 Christian Aid (DAS0019) para 3.12

131 Metcalfe-Hough, V., Keatinge, T. and Pantuliano, S., UK humanitarian aid in the age of counterterrorism:Perceptions and reality (March 2015) p7

132 Metcalfe-Hough, V., Keatinge, T. and Pantuliano, S., UK humanitarian aid in the age of counterterrorism:Perceptions and reality (March 2015) p7

133 Q49




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6 May 2016