Our safeguarding commitments | ActionAid UK

Our safeguarding commitments

As an organisation, we are committed to creating a culture and environment based on the principles of fairness, equality, respect and non-discrimination. 

We have a zero-tolerance policy on serious misconduct of any kind. Our commitment is to a transformative change in how we approach safeguarding and anti-sexual harassment, building on what process and policies we already have, but going far further than that by ensuring that the interests of beneficiaries (or ‘right holders’, a term that we prefer) and survivors are at the heart of a review of our practices and culture, especially the voices of women and girls.

ActionAid UK (AAUK) is a member of a global federation, ActionAid International (AAI). As a responsible member of the federation, we will promote a number of actions by influencing wider processes and through peer support among the members of the federation. Within ActionAid UK, we will directly implement actions that are within our remit.

Key actions we will take following the Safeguarding Summit

As part of our commitments following the safeguarding summit, these are the key actions (although not exhaustive) that we will be taking to deliver on the five commitments made at the Summit.

1.    Demonstrating accountability to beneficiaries and survivors and 4. Accountability through rigorous reporting and complaints mechanisms

We recognise that women and girls make up most of the cases, and are most vulnerable to harassment and abuse, especially due to abuse of power. We ask of all staff working with us in AAUK to take responsibility for the environment that they create, and the way in which they interact with their fellow colleagues and the people they manage, how they conduct themselves in terms of being aware of their power, privilege and position, and how they exercise this. We will tolerate no abuse of power.

ACTIONS we will take (not exhaustive) with reasons below them:

  • Streamlining, simplifying and making fully accessible to all staff and associated personnel our policies, protocols and procedures regarding safeguarding (in its widest sense).
  • We will undertake a mandatory review of our policies, practices and approaches to safeguarding every 6 months starting in September 2018 to ensure that these are constantly updated, refreshed as appropriate, and lessons learnt are factored into existing practices.

We will strengthen our policies and protocols related to safeguarding (including whistleblowing, complaints, anti-sexual harassment and safeguarding policies). Each policy and procedure will be simplified, accessible to all members of staff, and with a focus on being responsive to an incident and ensuring the safety of those coming forward. We will continually assess how successful these are, especially for women and girls. This will include explanations stating what they can expect from us, in what timeframes, who will be responsible for an investigation, and how feedback will be given to them. We will make this much more visible and clearer to other members of the AAI federation who receive funding from AAUK, to ensure greater awareness, and support them in developing similar approaches, whilst also encouraging them to do likewise with local organisations with whom their have partnership arrangements.

  • ACTION: Include safe and independent spaces for women and girls to disclose and hold us accountable for our behaviour within all programmes we design and/or fund, and continually assess how effective they are in terms of women and girls feeling confident and be able to disclose.

We will strengthen our accountability and reporting mechanisms within programme design ensuring best practice, and context appropriate systems. We will ensure that within every programme we are involved in designing and/or funding, that there is always a space for people to go that has independence from the management structure, and where they can hold us to account. In the past we have been able to include safeguarding within funding proposals and to enable us to provide these spaces, we will seek to do this moving forward.

  • ACTION: Continue to make mandatory the signing of a conduct agreement when overseas to reinforce that no-one should have unsupervised access to people we are working with, especially women and girls.

Currently all ActionAid countries involved in child sponsorship activities must adhere to strict ActionAid International (AAI) protocols that are designed to minimise risks to children. As a Federation we will review these protocols to ensure that they are as robust as possible and that expectations are explicit, signed up to, and monitored. All stakeholders visiting programmes (including donors, supporters, journalists, consultants, trustees and anyone else there on behalf of, or in association with, ActionAid) already sign a conduct agreement before travelling, and we will continue, as part of this, to demand that no-one be allowed unsupervised access to any beneficiaries of assistance.

ACTIONS:

  • Embed AAUK new images policy to protect child survivors of sexual violence, including content gathering and content storage;
  • Train staff in responsible and sensitive content gathering.

As part of our ongoing commitment to protect and support children and vulnerable people, we will build on both AAI and AAUK’s existing policies and protocols regarding the gathering and usage of stories, images and video of our beneficiaries. In recent years AAUK and AAI content has been gathered with strict levels of informed consent, which has included concealing the faces and full names of children when requested by parents, guardians or the children themselves, removing the surnames of all children and their parents, removing the locations, identifying landmarks and photo metadata of all children. Our new AAUK images policy, launched this year, will build on and further strengthen this commitment, to ensure that any images or videos of child survivors of sexual violence are gathered, used and stored in such a way that none of their faces are revealed. And we have already begun a retrospective project to remove such images from AAUK’s website by June 2018. To embed the policy, ActionAid UK will invest in training to conduct responsible and sensitive content gathering and ensure that all content is monitored and therefore compliant before it becomes accessible to others (on our website or internal channels).

ACTIONS:

  • Annual attestations from countries regarding compliance to Federation policies;
  • Internal audit plan from the Federation to focus on auditing compliance;
  • If AAUK are not assured after internal Federation channels are exhausted then AAUK will explore own measures, including withdrawing resources/funds in most serious cases.

AAUK will ensure that all parts of the Federation that we work with via memorandum of understanding (MOUs) continue to include adherence to all of our Federation policies aimed at safeguarding beneficiaries and survivors, including (although not exhaustive) anti-terrorism, modern slavery, child protection, and anti-sexual harassment. We will ask that countries sign annual attestations that they both comply with the policies and that they have mechanisms in place to ensure that all local partners also comply. Auditing adherence to policies is a critical part of any internal audit plan of the country by our internal Federation audit team. If AAUK is not assured after internal Federation channels have been exhausted, then we will explore our own measures, including whether to withdraw resources on grounds of non-compliance.

  • ACTION: Consortia memorandum of understanding to include policy and procedure assessment around safeguarding and anti-sexual harassment, decisions made as a result regarding AAUK participation in the consortia.

As part of the due diligence phase of working in consortia, we will assess all partners’ policies and procedures, and then make the decision whether we can either support the partner/s to be able to adhere to and implement the policies and procedures or whether we walk away. We will be explicit in our programme design regarding the fact that funding is conditional on the partner/s being able to evidence compliance with the full range of policies, and that we expect them to pass those conditions on to all partners in the MOUs they sign. AAUK will ensure that any consortium MOU also includes these provisions, ensuring that partner MOUs explicitly mention adherence to policies including safeguarding and anti-sexual harassment, and adherence to our code of conduct.

  • ACTIONWe will act on any recommendations for improving accountability in our forthcoming external assessment of our commitments to the Core Humanitarian Standards (CHS), implementing those under our direct control and promoting improvements at country or federation level using our leverage and funding mechanisms.

2. Tackling gender inequalities with a step change in organisational culture

To start this process within the UK, specific ACTIONS to address this for 2018 include:

  • Once a quarter the senior leadership team, with relevant staff, will review progress on safeguarding and anti-sexual harassment, and highlight any challenges or issues, communicating these to staff.
  • A gender audit will be completed in 2018 and then every two years thereafter with an action plan that is communicated and reported on to all staff after each audit.
  • Diversity and inclusion questions to be included within the annual staff engagement survey, and the resulting action plan to be communicated to staff, along with quarterly progress updates.
  • A diversity mapping exercise will be completed by mid-2018, the results and action plan will then be shared with staff. We will work with the internal Diversity, Inclusion, Power and Privilege group to improve in this area.

It is important to us that anyone who interacts with us feels confident and safe to report anything that makes them feel uncomfortable. An important element within this is our work on addressing gender inequalities. We have already undertaken work to define our culture and behaviours in line with our desire to embed feminist principles in everything we do, ensuring that the debate about power imbalances is a frequent one in terms of our ways of working.

Our internal communications will echo this to build an environment where individuals feel safe and confident to come forward and report any case of discrimination on any grounds – gender, race, religion, sexuality, disability, nationality. Our focus is on building a culture where this is central.

We will create spaces where women and other minorities or those who tend to be marginalised can speak up, building on our existing feminist forum, and ensure that they feedback to the senior leadership team on a regular basis to ensure that these commitments are kept front and centre.

3. Safeguards are integrated throughout the employment life cycle

We will be transparent regarding safeguarding practices right through the employee life cycle.  

ACTIONS:

  • Statement added to all advertisements regarding checks we will take around safeguarding;
  • No references will be given for individuals dismissed for breaches of safeguarding and/or anti-sexual harassment;
  • Investigations will continue even if the accused resigns part way through or before they commence;
  • No congratulatory email for service will be sent out;
  • Safeguarding and anti-sexual harassment to form key part of performance management approach, especially for senior leaders, and this will be evaluated as part of the annual staff engagement survey.

As part of our recruitment approach we will add an explicit statement around safeguarding and the checks that we will undertake to all our advertisements, building upon the work that we already do for roles where individuals are likely to have contact with our programmes. We will continue to include questions around safeguarding as part of the interview process for any role that is likely to have contact with our programmes, and as part of our referencing processes. In addition, we will not provide references for anyone who has been dismissed for breaches of our safeguarding and/or anti-sexual harassment policies and will continue to investigate even if people resign. We will make this clear to the individual so that they understand that we will decide based on the information we have, and therefore they can decide whether they wish to remain part of the investigation. We will also ensure that no congratulatory email for their service is sent out.

Safeguarding will also form an essential part of our performance management approach for all senior manager positions, relevant roles, and people who travel, outputs of which will be monitored and included within the discussions within our safeguarding forum.

5. Concerns are heard and acted upon

As outlined in point 2 we will continue to develop a culture where all staff and stakeholders understand how to raise issues around safeguarding and are comfortable doing so.

ACTIONS:

  • We will convene a safeguarding and anti-sexual harassment forum who will meet quarterly and actions / communications as a result to all staff;
  • Alongside this we will develop an external safeguarding advisory group;
  • We will ensure gendered travel briefings to include safeguarding / anti-sexual harassment as well as security, and post de-briefings to capture any issues / incidents, and will report back to the complainant on any issue / incident as appropriate; 
  • Investigation training for key personnel who will then be deployable to support the wider Federation;
  • Mandatory safeguarding training for all staff in 2018, and this will then form part of the induction for all new staff.

We have formally appointed a safeguarding focal point within AAUK who will oversee our approach to safeguarding and anti-sexual harassment in the UK. This person will convene a safeguarding and anti-sexual harassment forum on a quarterly basis consisting of a core team and inviting in appropriate specialists and individuals who have visited programmes to discuss any concerns or issues that we need to address. They will also develop this year a safeguarding advisory group consisting of external experts that we can refer to, to ensure that our practices are sound, robust, and best practice. This group will meet at least twice a year.

These actions are in addition to the whistleblowing avenues already in existence.

Our process for overseas travel is being strengthened, and we will ensure that all staff are briefed on safeguarding polices pre-trip alongside existing security protocols and focus on ensuring that these briefings are gender specific, especially in relation to risk assessments. On return they will have a more structured post trip de-brief with HR or their line manager to enable them to raise any safeguarding or sexual harassment issues.

AAUK will also commit to training key personnel in delivering safe and effective safeguarding investigations. This will ensure that any AAUK-specific disclosures can be acted upon effectively, safely and in a timely manner. We will also ensure that our investigation capacity is available for deployment within the wider Federation as required.  

In addition to the investigations training, AAUK will also deliver mandatory safeguarding training for all staff throughout 2018, as well as training to managers specifically around how to deal with complaints responsibly and responsively. This will be included within inductions for all new staff.

Working with the wider Federation

As part of a Federation, we recognise that local context is a critical factor in any implementation, that said the Federation has embraced the need to be bold, and focus on the rights of women and girls, which means that all parts of the Federation are signed up to improving the lives of the most vulnerable. The Federation have echoed our zero tolerance of any form of abuse, which means that cultural sensitivities cannot be used to stifle review, and where needed, reform. We will therefore be bold AND respectful in working with our colleagues and have enshrined in our safeguarding policy within the UK that funding to countries may be withdrawn if the response to an incident is not robust (in line with grant conditions in the UK and the legal context under Charity Commission regulations).

We will call on the ActionAid General Assembly to adopt a transformative agenda to ensure that we safeguard people, most especially women and girls, and protect them from sexual harassment, exploitation, and abuse. Our approach must be rooted in the experiences of survivors, and guidance from them on how to design effective procedures. It must also be in line with feminist leadership principles and designed to address the patriarchal attitudes and unequal power dynamics that underlie sexual harassment, exploitation and abuse. Further, any form of sexual exploitation and abuse perpetrated by a development or humanitarian practitioner should be seen as a gross violation of human rights.  

As part of our responsibilities to the wider ActionAid Federation, we will therefore work with the Global Secretariat in these areas: -

The Secretariat will be appointing a global safeguarding lead and we will support them to increase safeguarding capacity, particularly investigation expertise as this is a central aspect of any effective safeguarding function. We will therefore work with them to ensure that investigative capacity is a key priority (in terms of strengthening our approach). We will help the safeguarding lead write guidelines for all Federation members and their partners as to how reported incidents should be investigated which is then implemented throughout the Federation, and with partners. We will encourage, and work with them, to help ensure best practice around beneficiary-orientated disclosure mechanisms is adopted consistently across all members of the Federation.

We will ask them to strongly advocate for member countries to appoint a safeguarding focal point / lead at programme level in every country and that these focal points / leads are trained by specialist safeguarding experts, including conducting investigations, and that this is a mandatory element of them holding that position. These focal points / leads will then share expertise so that we continually learn and implement best practice from around the Federation. The focal points / leads will work with partners to ensure that policies are being implemented, and that we can support our partners (some of whom might be too small to have specific safeguarding expertise within their organisation).

We will ask them to work with us and all members of the Federation to implement minimum standards around our standard operating procedures that are relevant to all countries, which are then added to for a specific local context. We will ask that they ensure, through the annual attestation process, that no country is able to have policies and procedures that fall below these.

The Global Secretariat will bring a revision of the global child protection policy (to include vulnerable adults) to the Federation’s upcoming March Board meeting. We will support the Global Secretariat to embed this policy and encourage them to ensure that this policy, along with the anti-sexual harassment and whistleblowing policies, within the Federation focus on confidentiality and safety for those disclosing incidents, as well as a clear, consistent, and simple method of reporting.

We will support the GS to develop and resource a global safeguarding training programme to be rolled out to all staff and programme partners to ensure consistency, and the learning and replication of best practice that exists within the Federation.

The Secretariat is proposing a code of conduct for all staff to our Board and member’s General Assembly in June 2018. They are preparing a motion to the Assembly requiring that all country directors and Heads of HR undergo an orientation that focuses on the code of conduct and our values as a Federation, and that this code of conduct form part of the induction of any new employee moving forward.

We will further propose to the Assembly that any policy and procedure that is introduced within the Federation is translated by each member country, not just in terms of language but in terms of being relatable and relevant so that they can be used at community level. This will include the specific referral process for each country. This could then also be used for all overseas visitors so that everyone is aware of what they need to do if they see or experience anything that contravenes the policy / makes them feel uncomfortable.

We will ask that they explore the adoption of confidential and independent whistleblowing mechanisms that survivors would feel confident using to further strengthen our global whistleblowing policy and procedures, and to encourage individuals to report.

We will explore with members of the Federation an approach around restitution to survivors, how this might be funded and resourced.

As members of a Federation, we remain deeply committed to developing an organisational culture that promotes highest standards of accountability, responsibility, integrity and conduct, always being cognisant of how we use our power, privilege and position within any situation.

Footnotes

Page updated 31 July 2018