First Special Report
The International Development Committee published its First Report of Session 2019, Follow-up: sexual exploitation and abuse in the aid sector on 17 October 2019. The Government’s response was received on 20 January 2020 and is appended to this report.
Appendix: Government Response
General Points
DFID welcomes this follow-up report on sexual exploitation and abuse (SEA) in the aid sector and the International Development Committee’s (IDC’s) continued scrutiny on this important issue. This issue is regrettably not one that can be resolved in a short period of time. Sustained effort over many years is required. That is why safeguarding against sexual exploitation and abuse and sexual harassment (SEAH) continues to be a priority for DFID. The three reports we published in October 2019 on the anniversary of the London Safeguarding Summit are clear that many challenges remain, but also that DFID has helped drive significant progress during the year following the Summit. It is unfortunate that the publication of the IDC report ended up coinciding with that of our reports and so couldn’t take them into account.
But we know that SEAH still happens far too often and we must continue to do all we can to make zero-tolerance a reality. We recognise the challenges highlighted in the IDC report around support to whistle-blowers, coordination across different organisations working in the aid sector and accountability to victims and survivors. We are determined to drive progress on those and other issues. We have responded to each recommendation and question below, grouping some together when appropriate.
Response to specific IDC report recommendations/questions
1.Whilst culture change is an important part of solutions to SEA, it is not the same as having access to practical resources for receiving and responding to complaints, such as safeguarding staff, focal points and investigators. We note that DFID’s Resource and Support Hub does have the potential to provide this practical support: As part of its reply to this report, we ask that DFID set out clearly how exactly the Hub will be “offering support with investigations”, distinguishing between describing and signposting, on the one hand, and actual access to, and provision of, services, on the other.
We have previously underlined the need for both cultural change and access to practical resources. We signed the contract for the Resource and Support Hub (RSH) in December and have agreed a delivery plan with the supplier. The initial nine months of this programme will be a pilot during which we will engage with organisations across the sector, including to determine how best to support investigations. The programme’s online platform will go live in Spring 2020.
We expect the RSH to focus on signposting to professional services via regional hubs, rather than providing the services themselves. We feel this approach is more sustainable and will provide services which are best suited to local circumstances. Through its pool of experts, the Hub will pilot the provision of some mentoring support to selected organisations needing advice on SEAH investigations, which combined with the training of trainers and support to communities of practice will help build capacity and capability. The RSH plans to launch regional hubs in Ethiopia, Nigeria and South Sudan in 2020, with the potential to scale up to other countries and regions in the second year of the programme. In parallel we are exploring other ways not linked to the RSH to increase practical support for those involved in investigations.
2.We ask DFID to provide, as part of its reply to this report, a description of the planned steps—and associated resources—which will embed, promulgate and enable aid recipients to enjoy the rights contained in [the UN statement of victims’ rights] once developed.
The statement is not available yet and so we can’t respond with the level of detail required. The authors of the statement within the UN need to secure buy-in across the UN system. DFID has been supporting the work which we see as an important way to empower victims and survivors to come forward. Once the final version is available we will work with other parts of the UK Government to consider how best to amplify its messages and ensure that aid recipients can enjoy the rights it sets out.
3.As part of its reply to this report, we would be assisted by DFID setting out how many requests, and for how much additional funding, the Department has received and granted in relation to safeguarding since 2018.
It is hard to put a precise figure on this as DFID has thousands of live funding agreements at any one time and does not track spend on safeguarding specifically across all our programmes. In terms of centrally managed funding which has been specifically earmarked for work on safeguarding, we are spending at least £40 million between 2018 and 2023. We do not hold information centrally on programmes with a different primary focus, such as education or health, that have included safeguarding in their bids for funding. This funding is awarded on a case by case basis. DFID has made it very clear publicly and repeatedly that we will consider any request for funding for safeguarding activity in our programmes. DFID’s Safeguarding Unit have asked partners to flag unsuccessful requests for safeguarding funding as part of programme bids and are not aware of any cases since 2018.
4.At the International Safeguarding Summit in October 2018, we were pleased to see the emphasis that DFID placed on supporting the victims and survivors of sexual exploitation and abuse (SEA) and on strengthening reporting. The measures that DFID and Bond have presented to us which are aimed at providing better complaints mechanisms and improving responses to victims and survivors have the potential to be the first steps towards making this a reality. However, these measures place significant weight on developing the theory and substantially less on ensuring changes in practice. The final report of the Independent Commission on Sexual Misconduct, Accountability and Culture Change provided a stark reminder of how little has really changed for those who are exploited and abused by aid workers. DFID and the wider aid sector now need to place greater emphasis on ensuring that the changes to policy at organisational level are felt in practice by those living in humanitarian and development contexts who have experienced, or who are at risk of experiencing, sexual exploitation and abuse. DFID’s provision of resources through budget lines is a positive step, but the Department’s messaging on this needs to be clearer.
5.DFID should commit unequivocally to ensuring that any programme it funds where there are safeguarding risks has sufficient resources for safeguarding built into the programme. This should include, where required, provision for safeguarding staff and focal points operating at the programme level.
Government position: Agree
Changes are happening on the ground, but much more effort is needed from everybody involved. DFID has made it very clear publicly and repeatedly that we will consider any request for funding for safeguarding activity in our programmes, which includes for staff and focal points on the ground. We are also working with our partners to improve beneficiary accountability, complaints mechanisms, and capacity building of downstream partners. We will continue to ensure our messaging on this is clear and understood by partners.
6.As well as providing the resource, DFID should hold organisations accountable for how this funding is used. For example, DFID has supported Bond to develop a complaints and reporting toolkit and has committed up to £10 million towards the establishment of a Resource and Support Hub. The Department should now set out how they will monitor the implementation of the best practice guidance that is set out in the toolkit and which will be available through the Hub, to ensure that it has practical impact.
Government position: Agree
DFID carries out detailed due diligence on all organisations before providing funding to them, including on safeguarding, and we set out requirements in our funding agreements. We then monitor how our partners use the funding provided via our regular programme monitoring, setting clear expectations at the start of each programme about the outputs and outcomes we expect. The complaints and reporting toolkit is one of three pieces of guidance we funded to raise safeguarding standards in the NGO sector. We also funded guidance on safeguarding and governance (which has been published on Bond’s website), and a leadership and culture tool, which is in the process of being finalised. Each of these was developed by an NGO working group with support from Bond. We monitor our partners’ reporting mechanisms via our due diligence process and regular programme monitoring and will continue to do so. We don’t plan to monitor in detail whether guidance provided in an optional toolkit is used. But we will continue to engage with Bond and others via various mechanisms to check how useful organisations find the tool and if it can be strengthened, or if additional tools are required.
7.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.
8.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.
Government position: Agree
We agree that protection for whistle-blowers should form part of all frameworks for reporting sexual exploitation, abuse and harassment of both beneficiaries and staff. The March Summit did highlight the importance of support to whistle-blowers, but without agreeing to a systematic audit of whistleblowing as suggested by the report. DFID has provided leadership on whistleblowing, for example by incorporating whistleblowing as one of the six pillars in our enhanced safeguarding due diligence and ensuring that support to whistle-blowers has featured in key donor commitment documents. We are planning to publish in the first half of 2020 a synthesis of the main findings from the central safeguarding enhanced due diligence assessments which are currently underway. Whistleblowing will be included as one of the six areas that these assessments look at. Our enhanced safeguarding due diligence guide makes it clear that the assessment of a potential partner’s whistleblowing should examine not only whether they have a policy, but also how it operates in practice.
9.The gap between safeguarding policy and practice extends to the United Nations. The UK Government, now recognised as actively engaged on sexual exploitation and abuse at the UN, is well placed to press UN agencies towards implementation of best practice. In particular, the UK should use its position of influence as a donor to ensure that [UN] inter-agency community-based complaint mechanisms are widely and effectively established. This may involve actively funding such mechanisms to ensure that they are functioning in locations where multiple agencies are operating.
Government position: Agree
DFID is absolutely clear that United Nations partners must implement their SEAH policies. Since 2018 we have introduced tough new language on safeguarding for funding agreements with the United Nations. We can stop funding to any UN entity at any point if they fall short of the standards we require on SEAH. We recognise the importance of having functioning inter-agency community-based complaints mechanisms to ensure that people on the ground can come forward and report concerns. We will continue to engage with the UN on this issue, including through the Inter-Agency Standing Committee and as a Member State via the Executive Boards. We will continue to consider actively funding such mechanisms in specific countries on a case by case basis.
10.Whilst we were initially disappointed at the slow pace of collective action on safeguarding by DFID’s private suppliers, this seems more due to a lack of coordination than an absence of will. DFID must recognise the important role it can play as a convenor, ensuring that all aid organisations, both for-profit and not-for-profit, have the opportunity to share best practice and learning on preventing sexual exploitation and abuse (PSEA). Six months should not have passed after the International Safeguarding Summit before DFID began to facilitate these meetings.
11.Going forward, DFID should ensure that both the private suppliers and the NGOs it is funding are aware of and participating in cross-sectoral safeguarding forums. This will help to break down silos and facilitate coordination and information sharing so organisations can work together to drive up standards collectively on safeguarding across the sector. In particular, DFID should ensure all partners are aware of and connected to inter-agency PSEA networks and inter-agency complaints mechanisms in the countries in which they are implementing DFID programmes.
Government position: Agree
DFID is ensuring that NGOs and private suppliers are aware of and participating in cross-sectoral safeguarding fora which we convene. One of the objectives of the October 2018 summit was to break down silos and facilitate coordination. Since then we have convened, on a quarterly basis, representatives from all groups who made commitments to share lessons and challenges via a cross-sector safeguarding group (CSSG). This group allows the coordination of joint messaging across the sector and published a joint progress report on 17 October 2019. At the latest meeting in November, members of the group, including representatives of private suppliers and NGOs, agreed to continue to meet quarterly throughout 2020 to promote cross sector coordination, lesson learning and sharing of information. Other examples of DFID joining up the private sector and NGOs include DFID’s supply partner conference in September 2019 at which sessions on safeguarding throughout the employment cycle were jointly led by NGOs and private sector representatives. At country level, DFID offices are proactively promoting coordination via inter-agency PSEA networks and use of complaints mechanisms.
12.Voluntary self-regulation of safeguarding standards allows failures on sexual exploitation and abuse to slip through the cracks. In our view the case for an independent ombudsman remains strong. Without one, there is a risk that victims and survivors and their advocates will have no avenue through which they can appeal if the established reporting channels fail them and we see this as a huge, ongoing accountability gap. The ability to appeal to an independent body is a fundamental part of any fair system of justice and, to date, there appears little recognition of this within the sector. We welcome the development of the ombudsman proposal by the Dutch Government and we urge the UK Government, together with Dutch Government counterparts, to display international leadership in making the ombudsman a reality.
Government position: Partially agree
DFID remains strongly committed to improving accountability in the international aid sector. All of the work which DFID has been driving since early 2018 has focused on making it easier for individuals to report cases; for more and better support to survivors and victims; and for increased accountability of organisations and individuals who commit offences or don’t meet the high safeguarding standards we require of them. DFID has discussed the ombuds proposal extensively with other donors in the past year and there does not seem to be any support for an international aid ombuds or a clear vision of how a supranational body would work in practice. The emerging consensus is to focus on improving accountability and support at local and national levels. The inter-agency community-based complaints mechanism (CBCM) model is relatively new in operation, and it is important that we collectively review the implementation and impact. The Inter-Agency Standing Committee (IASC) Task Force are taking forward work on this and we will engage in the process.
13.At the height of the safeguarding scandal in 2018, aid organisations appeared to recognise that transparency on sexual exploitation and abuse is a necessary component of a full response and essential in breaking down the culture of silence and stigma that has so long inhibited victims from coming forward. Progress on this across the sector has been limited, with some organisations seemingly more willing than others to publish information about the number of allegations they have received and the outcome. Whilst there is consensus that organisations should be reporting this information to donors and the Charity Commission, we have not seen similar commitment to making data public. As a membership organisation of UK NGOs, Bond is well placed to promote transparency by setting an expectation that Bond members will publish annually information about the numbers of SEA allegations received and the outcome, and by monitoring which of its members do so. DFID should similarly set this expectation for private sector suppliers, non-UK NGOs and multilateral agencies, who do not have a membership body to play this role, but who should be equally pressed to improve transparency on sexual exploitation and abuse.
Government position: Partially agree
We agree that transparency is essential. DFID leads by example, publishing our reporting figures in our annual reports and accounts (most recently in July 2019) and encourages our partners to do the same. We are looking at how we can help others to strengthen data collection and reporting, recently raising this issue with our cross-sector safeguarding group, and have seen real progress as a result of donor discussions. For example, the UN have recently strengthened their online reporting of SEA allegations, including those of their implementing partners. Data is now published in real time (rather than quarterly) allowing an allegation to be tracked as it progresses through the system and identifies support provided to victims/survivors. Bond is encouraging their members to be more transparent about their progress on safeguarding and we welcome those efforts. Bond is not a regulatory body and therefore is not mandated or resourced to require its members to publish data on numbers of SEA allegations, or to monitor this. For non-UK NGOs and multilaterals, DFID includes language on transparency in specific funding agreements on a case-by-case basis, but we cannot insist that they report figures for all of their work.
Published: 13 March 2020