This paper calls upon international nongovernmental organizationsFootnote 1 (INGOs) to critically reflect on current approaches to safeguarding vulnerable individuals from communities and within organizations from sexual exploitation and abuse (SEA)Footnote 2. By providing an insider perspective, this paper critically evaluates two prevailing INGO approaches. It concludes that a centralized approach promotes power hierarchies and control, limiting an organization’s ability to address SEA cases effectively. In contrast, the cultural transformation approach within organizations represents a more successful means of managing the issue of SEA in the humanitarian sector. My conclusions are based on over two and a half decades as a humanitarian aid and development worker, most of which was spent in senior leadership and advisory positions. I led humanitarian responses and development programs in Asia, Africa, and Europe, in addition to lobbying stakeholders, including United Nations officials, diplomats, politicians, and government decision-makers, to promote accountability and safeguard the rights of refugees and other vulnerable individuals. My efforts to ensure the accountability of perpetrators of workplace crimes and the protection of vulnerable populations are predicated upon my appreciation of the power wielded by humanitarian and development actors over individuals and communities in crisis.

In 2002, public awareness of SEA by humanitarian aid workers in West Africa resulted from a report by a UNHCR/Save the Children assessment team in Guinea, Liberia, and Sierra Leone. The team encountered allegations of the extensive sexual exploitation and abuse of refugees and internally displaced women and children by humanitarian workers from 42 agencies that involved 67 individuals (UNHCR and Save the Children, 2002). Efforts were made to discount these allegations. In October 2002, the UN Office of Internal Oversight Services (OIOS) stated that its investigation found no evidence of widespread abuse. This prompted claims that the UN was engaged in a cover-up (Naik, 2003). Ultimately, the West Africa Food for Sex Scandal triggered attempts to remedy weaknesses in prevailing mechanisms to prevent abuse, including establishing the ‘Humanitarian Accountability Partnership International’ in 2003. The partnership sought to bolster accountability towards crisis-afflicted persons, thereby acknowledging the need to improve extant PSEA laws, culminating in the UN Secretary-General’s 2003 Bulletin, Special Measures for Protection from Sexual Exploitation and Abuse (PSEA) (ST/SGB/2003/13), which was formally adopted by the UNHCR in 2004 (UNHCR, 2022). Other indications of change include the 2015 Donovan’s Code Blue campaign, which increased pressure to end sexual exploitation by UN peacekeepers. Unfortunately, neither these efforts nor the associated policies discernibly halted sexual exploitation in the humanitarian and development sector. In February 2018, Oxfam was accused of suppressing evidence that staff had sexually exploited survivors in earthquake-hit Haiti in 2011 (Sky News, 2018). The consequent media coverage caused INGOs to review their safeguarding policies and practices (Gayle, 2018). However, subsequent reports indicated that abuses of power by INGO personnel had not ceased. For example, The New Humanitarian (2020) published a report that voiced the experiences of survivors of sexual abuse by aid workers during the Congo Ebola crisis. Another expose was published in the Guardian by Karen McVeigh (2021) titled “Aid sector is ‘last safe haven’ for abusers, UK investigation warns”. Other evidence indicates that personnel in INGO offices are vulnerable to exploitation in exchange for promotion or other material benefits (Specia, 2021).

Protection from sexual exploitation and abuse (PSEA) includes child safeguarding. Moreover, it aims to ensure that allegations of sexual exploitation are addressed promptly and appropriately (IASC, 2022). The “do no harm” ethos incorporated within PSEA focuses on the protective environment of susceptible communities. Thus, commitment to PSEA is central to the preservation of the dignity of both vulnerable communities and workplace colleagues. This requires INGOs to establish (a) safe and accessible community-based reporting mechanisms whereby survivors can access (a) assistance, (b) funding, and (c) dedicated human resources to ensure that incidents are investigated quickly and competently. Communication channels must ensure donors and statutory authorities receive reports in a timely fashion. Moreover, staff members, service providers and stakeholders need training to raise awareness of PSEA, reinforced by improving vetting, reference checking, and disciplinary measures.

On a personal level, implementing the PSEA in various INGOs, including their partner NGOs, has been a major learning process for the last two and a half decades. I have also attempted to exchange views and discuss lessons learnt with my peers. My own reflections have led me to conclude that INGOs can be broadly divided into two types referring to establishing PSEA mechanisms: those that focus on centralized strategies and those that emphasize cultural transformation. Although the paper provides critical feedback on the centralized strategies and argues for adopting a cultural transformation approach, the dichotomy between these two approaches must not be seen, as there are zero benefits of the former and zero weaknesses in the latter. Mostly INGOs have favored the centralized approach, as it minimizes the risk of missing out on any allegations followed by seeking complete control over SEA crises. Some INGOs favor a less authoritarian approach. The cultural transformation approach was adopted to address structural limitations in the centralized approach. Although the effort towards cultural transformation is a positive step forward, it does not necessarily address several critical issues, such as the organizational preference to maintain the confidentiality of perpetrators, the lack of organized sharing of information for reference checking during recruitment, etc. Thus, this paper examines the effectiveness of existing PSEA mechanisms among these two groups of INGOs and illuminates critical issues that require attention.

INGOs with a centralized approach

INGOs in this category have focused on developing a centralized reporting and investigation system to manage PSEA. The system encourages staff members and stakeholders, such as local partner organizations, target communities, and service providers, to register all forms of complaints if the complainant considers the accusation a matter of concern. This has created avenues to register SEA and other concerns easily. The term registration refers to a complainant making a complaint. A high number of registered complaints is deemed to indicate successful PSEA implementation. However, this is not necessarily true.

Although there exists a mechanism to sort out complaints under various categories, such as human resources, procurement, and sexual exploitation, the process of distilling out SEA complaints from the pool of registered complaints could be time-consuming because of various reasons, such as insufficient information and language barriers. Often there is a considerable delay for the survivor to receive due attention from the organization. In certain contexts, delay even by a few hours in responding to complaints could cause irreversible harm to the survivors. I encountered a situation where an internally displaced woman filed a complaint in her native language, accusing a health worker of inappropriately touching female clinic patients. Initially, the concerned person filtering complaints sought support from various people at the headquarters to read and understand the contents of the complaints. I received the complaint at the country program office a few days later with a request to support translation. I could easily facilitate the translation of the complaint with the help of someone who spoke the same language. It was immediately categorized as a SEA case, and necessary measures were taken; however, the procedure was long drawn out.

In my experience, a centralized reporting management system followed by a centralized approach to investigation leads to more inefficiencies. Organizations typically establish stakeholder groups to manage complaints and investigations, and these groups assume a superior stance, often selecting members from organizational headquarters, which could lead to low standards in the investigation process. Thus, case investigations may be tardy, inconsistent, or incompetent. Investigators are frequently unfamiliar with the reality of abuse and have a scant understanding of how to corroborate or dismiss complaints. For example, an investigator who manages complaints made by refugees must understand basic refugee rights and the legal frameworks of diverse nations. I have spent considerable time educating investigators about these basics to assist investigations. I also encountered the dysfunctional aspect of this investigation approach in one INGO that hired a senior manager in its country program office. Soon, the new manager faced accusations of bullying by two of her male counterparts; in addition to the accusation, she had also used forgery and information concealment to gain employment. At the country office level, background investigations were launched to address forgery, and a separate dialog with the new manager was initiated regarding the allegations of bullying. Instead of showing commitment to resolving the bullying issue, the new manager launched a counter-complaint against male staff members claiming sexual harassment. The evidence unequivocally proved her guilt about forgery. Hence, the country office leadership team decided to suspend the new manager until the investigation of the SEA case was concluded. However, headquarters disregarded these findings and convened a stakeholder committee devoid of the country office leadership. This visible indifference was rationalized by the suggestion that protecting the organization’s reputation in dealing with SEA cases was necessary. However, it also concealed disinterest in any advice from the country leadership team. Hence, the suspension of the new manager on the ground of forgery was overruled, and the male employees were labeled guilty before any evidence was produced. Three months later, evidence emerged that the new manager’s claim of sexual harassment was false and that she had also been dismissed from her previous employment following serious allegations. Based on this evidence, she was summarily dismissed, but the centralized approach to investigation irreversibly damaged organizational culture and co-worker relationships. In a nutshell, this approach to PSEA also has the potential to erode trusted relationships, which is caused by the absence of deliberate and effective coordination between INGO headquarters and their country offices. The most important aspects of INGO work often occur at the community level of the country program. Stakeholders at the country office must remain pivotal to the PSEA.

Organizations maintain their investigators at headquarters, which means investigations are conducted from distant locations with an evidence-based modality that fails to incorporate broader perspectives, including threats, vulnerability, and the psychological condition of survivors. Investigators seek evidence in the form of video clips, recordings of any conversations, social media chats, etc., which is a challenge for survivors. This approach engenders a complex, distrustful work culture wherein individuals fear that their comments may be recorded. There is a bias favouring documented evidence at the expense of reliable testimony results in weak processes that are unlikely to result in a meaningful conviction. This derives from a headquarters-driven approach instead of a more locally owned one.

Investment in PSEA is typically headquarters-centric, whereby organizations possess dedicated human and financial resources designed to register and investigate cases. The chronically inadequate investment at the country office renders it impossible to develop any capacity to manage PSEA cases and raise functional awareness of PSEA. In addition, PSEA awareness-raising training is typically certificate-centric. Staff members must complete online PSEA training and submit certificates to the human resource department as confirmation. However, online training materials are often not in a local language, thereby diminishing the content value for the large group of staff members at country offices. Hence, the intended purpose of the course may not be achieved.

Organizations typically emphasize the development of centralized documentation systems. The interest in extensive documentation is prompted by a desire to focus on defensive mechanisms rather than promptly listening to survivors. Defensive mechanisms denote an organization’s capacity to use social and mainstream media to safeguard its reputation and legal obligations. Organizations focus on evidence and process, in preference to examining the broader picture or applying survivor-centered principles. Attention is devoted to evidence collection, the formation of stakeholder committees, the development of Terms of Reference, the generation of detailed documentation, the endorsement of the investigation outcomes by stakeholders, the processing of investigator recommendations, the appeal process, and the reinvestigation process. Stakeholder committee approval is frequently required for each stage. However, time is wasted because country office stakeholders are excluded, the internal bureaucracy is extensive, and the PSEA documentation is sizeable.

Consequently, perpetrators can exploit the protracted process and continue harming their survivors. As a country representative of one INGO, I encountered a case of sexual harassment against a female refugee who was working as a casual staff member in the branch office. I immediately registered the case in the organization’s system and traveled abroad. Upon returning, I discovered that her work had been discontinued due to gossip about the leaked incident. Eventually, I intervened and learned that gossip around her allowed the perpetrator to create a bad image of her at the workplace. Subsequently, I asked for her reinstatement while also enquiring about the investigation’s process. Later, I learned that the process was delayed owing to the stakeholder committee’s approval of the Terms of Reference. With my active persuasion, the headquarters acted swiftly to protect the survivor from further harm caused due to the long investigation process.

There is evidence of abusing the system by registering false complaints by staff members. In sexual harassment investigations, a false allegation is one the complainant brings, knowing that what is alleged did not occur and, therefore, could not constitute sexual harassment (Burr, 2011). Although there are no authenticated data from the humanitarian and development sector to establish the percentage of false complaints that the sector addresses as a part of the SEA process, various studies in developed countries suggest that the prevalence of false reporting on sexual harassment is between 2 and 10% (Lisak et al., 2010; Ferguson and Malouff, 2016). The given settings in which INGOs operate trigger the registration of false complaints. For example, societal hierarchy and identity, power-centric workplace culture, uncertainty with a job, etc., could lead to animosity in the workplace, resulting in the culture of registering false complaints. Punitive measures are rare for staff members who malevolently register false complaints. In various capacities, I directly engaged with six INGOs. As a part of this engagement, I had to sign their PSEA policy, only one of which was explicit about punitive measures to falsify PSEA complaints. Staff members who register malicious complaints undermine PSEA objectives due to the psychological impact of false accusations on the accused.

This centralized approach engenders a culture of mistrust. The absence of punitive measures for registering maliciously intended false complaints means that staff members are unafraid to register false complaints against their colleagues. This has impacted working relationships, encouraged colleagues to view each other with suspicion, and caused managers to revise how they manage staff members. This strategy also undermines the preparedness of managers and supervisees to be supportive of the fear of being misunderstood. For example, during performance reviews, line manager feedback to employees or vice versa can be registered as a complaint, thereby triggering an investigation and diverting resources from genuine SEA issues.

I have encountered situations where organizations with centralized approaches have failed to act against their senior officials. On one occasion, I was approached by a female colleague who accused a senior official (from the headquarters) of harassment. I registered a complaint against that person. Subsequently, I encountered an accusation against the same female colleague. The investigator of the counter-complaint was the individual who she had previously accused, despite the conflict of interest. Hence, he found a way to chase his former accuser out of the organization. Irrespective of whether the allegations were genuine, the worrying issue is that the leadership at the headquarters asked the alleged perpetrator to investigate a case against his complainant. Colleagues have provided me with anecdotal evidence of comparable cases. Although there is no indication that this practice is widespread, it still warrants investigation.

INGOs focusing on cultural transformation

Cultural transformation involves progressively modifying organizational culture, values, and practices. The process commences with experiences that encourage mindset shifts and provide the impetus to behave differently in a sustained manner (Bhalla et al., 2020). At its simplest level, cultural transformation to strengthen the PSEA concerns the transformation of INGO culture so that staff members (a) feel safe, (b) communicate constructively and respectfully, (c) respect diversity and display integrity, (d) consciously change their attitudes from power-centrism to service-centrism, (e) create a fair environment, and (f) acknowledge the perspectives of vulnerable communities in the delivery of development and humanitarian aid. Staff members must safeguard the dignity of their colleagues and the communities they serve.

The promotion of cultural transformation to bolster PSEA is assisted by introspective leadership that (a) appreciates the difference between prevailing INGO culture and the desired culture, (b) is committed to commencing cultural transformation with cognitive self-transformation (Kegan and Lahey, 2009), (c) promotes mindset and behavior change via suitable communication, training, and recruitment processes, and (d) modifies policies and processes to address the structural limitations of the organization (Munday, 2019). INGOs that emphasize cultural transformation can defuse power structures and encourage zero tolerance for abuses of power. These organizations have invested in PSEA awareness by (a) allocating roles and responsibilities to all stakeholders to reinforce preventive mechanisms, (b) encouraging clear communication during the registration and management of cases, (c) discouraging bureaucracy in the investigation process, and (d) providing feedback about investigation outcomes.

Change is typically progressive. Cultural transformation emphasizes establishing mechanisms that mobilize staff members irrespective of their position, thereby encouraging them to hold each other accountable. Introducing these mechanisms to organizations requires a transformative leader with integrity and the ability to inspire team members to create positive change. Such leaders must understand the full context of the problem prior to taking any action. For example, when working with one organization, I encountered a repeat perpetrator who had worked for the organization for many years as a senior leader. The perpetrator had been investigated on several previous occasions but was always acquitted due to a lack of evidence. When I joined the organization, some of my new female colleagues expressed a desire for justice. I rapidly realized that my failure to act would indicate my acquiescence to the prevailing power structure. Furthermore, the survivors would lose faith in the organization. I lobbied with the organization’s headquarters so that external investigators re-examined the cases. The external investigator produced a report that resulted in the dismissal of the perpetrator. Defusing the long-prevailing top-down management structure and executing a flat management structure created multiple avenues for voices from the periphery, including implementing measures intended to encourage female colleagues to report concerns and the creation of space for conversations between the senior management team and the other staff members.

The decentralized approach allows headquarters and country program offices to work collaboratively to manage issues and maintain trusted and respectful relationships. Moreover, organizations operating in accordance with a decentralized approach explicitly state that false allegations by any staff member will result in disciplinary action. These organizations have zero-tolerance policies with respect to SEA, as indicated by their rapid and reasonable responses. Moreover, they appreciate the structural limitations associated with securing hard proof of abuse and acknowledge reality by collaborating with the country offices. These organizations regard cultural transformation as an upwards and downwards process and respond positively to improve organizational policies and practices. Their leadership teams maintain connections that help them understand PSEA dynamics in diverse contexts and reinforce attempts to locate enduring solutions to address SEA. Organizations devote resources to capacity building for staff members and service providers and partner NGOs to enable them to strengthen PSEA at the organizational level. Organizations prioritize translating the code of conduct and PSEA policies in the local language, PSEA training for staff members and stakeholders in the local language and setting up community-based compliant response mechanisms to facilitate cultural transformation and strengthen PSEA.

It is important to monitor the effectiveness of the cultural transformation approach. Developing an organization-specific monitoring framework and using culture surveys are important in capturing the feedback of staff members and communities on the approach. Several indicators could be prioritized to assess the effectiveness of the approach. Examples include (a) the number of complaints registered in the system, cases resolved, and the proportion of false complaints detected, (b) the timeliness of handling the registered cases and the time taken to resolve the cases, and opinion of the country leadership team about their active participation in resolving the cases, as appropriate.

Issues requiring urgent attention by most INGOs

Ensuring confidentiality throughout the registration and investigation processes is essential when dealing with SEA cases. However, maintaining the confidentiality of perpetrators deserves a critical look, particularly when cases have been concluded. Instead of taking stern action against the perpetrators, organizations often employ a nuanced approach to removing a perpetrator by asking the employee in question to tender their resignation. Another strategy used is to simply not renew their job contract. However, this strategy can allow perpetrators to seize the narrative and present their departure as the consequence of a managerial issue. The principal reason for employing this strategy is the wish to avoid litigation. However, it renders it possible for ex-employees to repeat their misconduct at other organizations. In other words, the real problem is not addressed. Rather, it is simply shifted elsewhere. It also risks generating discontent between the country program office and staff at headquarters.

Another disadvantage of the confidentiality approach is that accused employees who are subsequently vindicated will never know who fallaciously accused. Furthermore, even when they are confidential, protracted investigations often generate suspicion. Work relationships are disrupted, and the workplace is transformed into a source of stress and misgiving for those directly interrogated in the investigation. In addition, there is seldom any support for staff members who have been falsely accused. Hence, they must manage any consequences of the trauma alone.

Despite the care organizations take with respect to reference checking during recruitment, the organized sharing of information about previous misconduct remains undeveloped. My personal experience has revealed that accurate references are only obtained through professional relationships and confidential discussions (linked with PSEA) about candidates. Moreover, I have discovered that former employers are seldom comfortable disclosing information about past sexual misconduct considering both legal and security consequences. Organizations emphasizing cultural transformation are becoming more interested in alternative strategies, including informal background checks from reliable sources and verbal reference checks with line managers. Conversely, process-oriented organizations emphasize written references, regarding them as more reliable than verbal information. Organizations must consider legal compliance when providing references. However, there is a clear need for innovative solutions in this area.

Convincing partner NGOs to implement the same approach as INGOs is also challenging. Frequently, the PSEA policy of INGOs is simply superimposed on partner NGOs. Variations may be introduced to secure donor grants. Thus, when PSEA cases arise, INGOs often fail to support their partner NGOs with their investigation. Rather, the INGOs assume responsibility for the investigation process, thereby successfully confounding attempts to address PSEA. Interventions by INGOs destabilize the competencies of local organizations and introduce delays. INGOs must appreciate that the partnership approach defuses power relationships. INGOs and partner NGOs are responsible for sustaining a relationship based on trust.

Occasionally, community members report concerns about volunteers who come from the community. Typically, the volunteer in question is merely replaced with another volunteer by INGOs or their partner NGOs. This can generate local disquiet since dismissing a volunteer without an investigation is deemed unjust. It is also important to reflect on whether it is appropriate for organizations to address the issue that could be dealt with by the community themselves and/or law enforcement agencies.

Limited resources, the need to avoid legal complexities, the short duration of projects, and the fact that project-based activities frequently oblige organizations to provide staff members with various types of job contracts. Non-permanent or short-term casual workers have a lower power status than staff members with permanent contracts. This can cause casual workers to feel dependent upon permanent employees to renew their contracts. Variations in contract types in the country offices inevitably generate a power imbalance in the workplace and facilitate exploitation. Awareness of this innate power imbalance and investment in cultural transformation helps organizations eradicate exploitation and abuse.

Concluding remarks

The relationship between humanitarian/development workers and vulnerable individuals is inevitably imbalanced. Therefore, PSEA is essential to safeguard vulnerable women and children from exploitation and abuse. INGOs now regard PSEA as essential. Nevertheless, I argue that organizational encouragement to register complaints is necessary but insufficient to provide colleagues a safe working environment and protect vulnerable groups, including women and children. The centralized approach to PSEA comprises a top-down power relationship between INGO headquarters and country offices. This approach fosters internal organizational bureaucracy, in contrast to directing attention to the voices of survivors and applying survivor-centered precepts to safeguarding practices. INGOs that employ this approach must review their PSEA strategies, encourage transparent discussions, take positive action to decentralize existing approaches, and appreciate the counterproductive character of prevailing power relationships between the headquarters and country program offices with respect to PSEA in the humanitarian and development sector.

This paper recommends that extensive investment is directed towards cultural transformation in humanitarian and development organizations. INGOs vary considerably. Hence, approaches would need to be tailored (Munday, 2019). Extensive investment refers to allocating resources to setting up a structural system (people, tools, and methods such as surveys, training, awareness-raising activities, etc.) that is required to facilitate cultural transformation within the organization. However, it is essential that every INGO secures a suitable strategy, investment plan, and appropriate team to ensure that the PSEA is bolstered by cultural transformation. Cultural transformation affiliates people with tasks and people with people (Immel, 2021). It also reinforces PSEA through the establishment and mobilization of teams that are based on collaboration, accountability, and safety, irrespective of the status of the individual team member. This also applies to vulnerable communities and program participants. Transformed cultures prefer decentralized approaches wherein headquarters and country offices work collaboratively to manage PSEA issues using a survivor-centric approach. Transformative leaders are pragmatic and adopt positive actions to allow organizational policies and procedures to bolster PSEA. Transformed culture permits employees to identify ways to collaborate and address key issues, thereby ensuring that the workplace is free from exploitation and abuse.

INGOs must engage in the collaborative search for innovative solutions to complex challenges. It is necessary to consider whether confidentiality clauses protect perpetrators and render PSEA less effective. In addition, types of job contracts must be reviewed to determine whether they render other employees vulnerable to exploitation. It is also necessary to reassess the value of existing legal barriers to the sharing of information about previous sexual misconduct. INGOs have the power to set new standards and promote change, and comprehensive information sharing across the INGOs would be instrumental for it, such as information about perpetrators, number of cases registered, number of false complaints identified, time spent for responding to the survivors and close the SEA cases and lessons learnt.

Finally, as of now, I could not find any academic literature that directly connects PSEA and cultural transformation in the humanitarian and development sector. I have attempted to connect these two aspects in this commentary by placing experiential learning. One of the aims of this paper is to encourage researchers to do further work in this field, as it would add immense value both for academics and the humanitarian/development sector.