Safeguarding and PSEAH – what’s next for our sector?

In the past week, USAID starting its listening tour with its implementers to receive feedback on their recently released draft policy for preventing sexual abuse and exploitation. This included a rich dialogue with Humentum’s members on Tuesday. Meanwhile, our sector has been rocked again by a high profile incident of alleged sexual abuse. Last week’s incident led to the resignation of Mercy Corps’ CEO, as well as a long-serving board member and another senior member of staff. It is notable in the Mercy Corps case that the strongest calls for the CEO’s resignation came from the staff—not the media, the board, or other external groups. This reflects both the strong values-based culture of Mercy Corps and is also an inflection point in our sector. It is a testament to the investments made in the past 18 months by many in our sector with respect to training, new policies and improved processes to encourage reporting of alleged incidents, as well a zero-tolerance for inaction.  Indeed, USAID’s newly released policy is centered around both a survivor-centered approach and a zero-tolerance standard. The response by the sector is therefore increasingly swift and clear when stakeholders, including staff, believe that our organizations and our leaders have not walked the talk.

Yet, in conversations with Humentum members over the past few months, within our own team at Humentum, and even with staff at Mercy Corps last week, it is clear there are several systemic gaps to address.

1. Insufficient capacity to manage the scale of investigations required to meet the benchmark of “zero tolerance for inaction.” As expected, by introducing updated policies and training, the number of reports and allegations are going up. In every conversation I have had with our members, they are reporting dramatic increases in the number of reports and are challenged to keep up with investigating them. They lack sufficient internal capacity and are unsure where to turn for a deep reservoir of external support. The reality is that there is also insufficient capacity available across the sector to help organizations manage this surge. The risk now is that if we fail to investigate fully and promptly, we will be seen to be making empty promises to our donors, staff, and the communities we serve.
2. A lack of standards to ensure that investigations are of high quality, fair and can be relied upon to take action. There are two inter-locking components of our sector’s approach that require higher standards. (1)  The need to take appropriate action against perpetrators of this type of abuse and harassment and (2) to prevent “bad actors” from moving from one organization or one country to another. Achieving these objectives, consistently and across the sector, requires shared agreement on the depth, quality, and thoroughness of the investigations for the outcomes of those investigations to be accepted and credible. We currently lack agreed standards for safeguarding investigations, so the risk is that different organizations, different donors or different governing jurisdictions won’t trust or accept the outcomes, decisions, and corrective actions taken by others.  
3. A more holistic and systemic view of safeguarding that goes beyond compliance. This requires an approach that integrates legal, HR, programs, and compliance. This includes a rigorous assessment of how our safeguarding policies and approaches align with other aspects of the organization’s culture, governance, human resources, risk management, and cascading of policies and capacity to our partners and sub-awardees. The risk is that without a deep understanding of these integrated elements and/or a lack of alignment, the organization is vulnerable to breakdowns that will lead to failures to prevent or respond appropriately.
4. A new approach to addressing allegations against senior staff, board, partners, and high profile volunteers and donors. Most organizations have applied their policies to their senior leadership and boards. These individuals have completed the same training that all staff have completed. As a compliance activity, we have checked the box. The insight from this past week’s Mercy Corps situation, and its similarity to other high profile cases at other organizations, is that this approach does not go far enough. We need to prepare senior executives and boards on what to do when (not if) they receive an allegation against senior staff, board, partners, or high profile volunteers and donors. Senior staff and boards need specific processes and policies prepared in advance for just these situations. And they need to rehearse those processes in high-quality simulation training—just as we might rehearse other high-risk situations such as active shooter in our offices, or hostage-taking in our compounds. The training and dialogue needs to address how we will safeguard our entire organization in these situations—which goes against the natural human instinct to protect those closest to us from harm or reputational loss.

Humentum plans to engage more deeply around these four issues in the coming weeks and months with our members, the donor community, and with our industry partners. I invite you to get in touch if you are interested in joining us in these next steps on the journey.

I have also been reflecting on our own organization. Like of all of you, we have further to go with our own steps in this journey so that our team, our member community, and our partners can hold us accountable to the same high standards. We look forward to working with the entire sector both as a convener and curator of solutions but also as a peer as we all strive toward protecting anyone who is at-risk and vulnerable in our work.

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