16.At a Summit on Safeguarding co-hosted by DFID and the Charity Commission in March 2018, participants agreed to “plan for a systematic audit of whistle-blowing practices across the sector to ensure individuals feel able to report offences”. In our July 2018 report, we welcomed this audit, recognising that protection for whistle-blowers is essential for ensuring that staff are safe from reprisal, whether they are advocating for beneficiaries who have been victims and survivors of SEA, or raising concerns about the abuse and harassment of staff. We recommended that “the remit of the audit should go beyond an examination of what exists at the policy level, and should test the extent to which systems and protections are working effectively”. We were therefore disappointed when the Government’s response to our recommendations, received in November 2018, stated that this audit had not been carried out because the NGO working groups had not deemed it to be necessary in addition to existing research. We pursued this in oral evidence on 7 May 2019 with Frances Longley, representing the four safeguarding NGO working groups, coordinated by Bond. Ms Longley indicated that whilst the NGO working groups had not pressed DFID to carry out the audit, they had not obstructed it. They saw it as DFID’s role to take the audit forward:
As I understand it, it was a piece of work that DfID was going to do, not the NGO sector. If DfID wants to do it, we are very happy for it to do so. I think all the working group said was that it was not an urgent piece of work… The work was for DfID to do, rather than the NGO sector.
17.Regardless of who was ultimately responsible for the audit not taking place, both DFID and the NGO working groups agreed that the audit was unnecessary, due to the fact that the Violence Against Women and Girls (VAWG) Helpdesk has already produced research, commissioned by DFID in early 2018, on the “Effectiveness of Whistleblowing Approaches”. It remains unclear, however, how effective this research has been at improving whistle-blowing policies in practice: when we wrote to Bond to ask what NGOs had done to change or improve their approaches to whistle-blowing on the basis of the research, the CEO of Bond, Stephanie Draper, responded that Bond “would not be able to collect information from members that would allow us to attribute changes in individual NGOs’ approaches to whistleblowing to this helpdesk research”.
18.We were perplexed to hear that one of the reasons why NGOs had not considered whistle-blowing to be a priority was because whistle-blowing:
though well-understood in the global north, is not an established part of many of the cultures where we work. Some common methods for whistleblowing, such as a phone number or an email address, are often not accessible or trusted in contexts where we work.
We found it surprising that this was presented as a reason for deprioritising whistle-blower protection, rather than as an argument in favour of ensuring that whistle-blowers, wherever they may be working, are able to report and be protected if they do so. We do note, however, that in later correspondence, Bond indicate an openness to work with DFID on improving whistle-blowing practices going forward.
19.In oral evidence on 7 May 2019, the Head of DFID’s Safeguarding Unit, Peter Taylor, told the Committee that checks on whistle-blowing policies are built into DFID’s due diligence assessments. Mr Taylor also said that whistle-blowing is included in the detailed central assurance assessments that DFID has carried out on 16 NGOs, although we note that these do not cover the private sector. The then Secretary of State, Rory Stewart MP, asserted in the letter following up to the evidence session that these assessments are having a positive impact on whistle-blowing policies: “we are seeing tangible evidence of partners strengthening their whistle-blowing approaches and that of their implementing partners as a result of the introduction of our enhanced safeguarding due diligence standards last year”.
20.Protection for whistle-blowers should form part of all frameworks for reporting sexual exploitation, abuse and harassment of both beneficiaries and staff. We have not yet seen sufficient attention being given to monitoring and improving the effectiveness of whistle-blowing policies and we are concerned that the importance of protecting whistle-blowers has so far been downplayed. The systematic audit of whistle-blowing practices that was agreed upon at the March 2018 Safeguarding Summit has seemingly been shelved. Both DFID and Bond have seemed reluctant to take responsibility for driving up standards on whistle-blower protection.
21.We are not convinced that the VAWG helpdesk research on whistle-blowing is a substitute for a systematic audit of whistle-blowing practices across the sector, particularly as we have not seen any evidence that this research has had a tangible impact on organisations’ approaches. If DFID’s assessment of whistle-blowing policies through its enhanced due diligence and central assurance assessments is having a positive impact and raising standards, then DFID should make its findings and recommendations publicly available, so that other organisations can benefit from this learning. If DFID is not willing to publish the findings of these of these assessments as a learning tool, then it should work with Bond to conduct and publish a systematic audit of whistle-blowing practices across the sector, as was previously agreed in March 2018. As we said in our first report, it is vital that this audit takes into account not just the existence of whistleblowing policies, but also their effectiveness in practice.
29 GOV.UK, , March 2018, Accessed 2 October 2019
30 International Development Committee, Eighth Report of Session 2017–2019, “”, HC840.
31 International Development Committee, Tenth Special Report of Session 2017–2019, “, HC1764
33 Bond (); Department for International Development Annex C ()
34 Bond Annex A ()
35 Bond ()
36 Bond Annex A ()
38 Department for International Development Annex C ()
Published: 17 October 2019