Tracking Allegations of Sexual Exploitation and Abuse Business Process Review

The Alliance is an intra-Agency working group charged with leading efforts to address and prevent sexual misconduct. In order to carry out this principle, the Agency made public declarations of its dedication to addressing sexual exploitation and abuse (SEA), including issuing a policy statement, clarifying existing grant standard provisions and contract clauses related to implementing partner (IP) codes of conduct and SEA reporting, and serving as a signatory to 22 safeguarding commitments made by international donors and non-governmental organizations (NGOs). The Agency's commitment to addressing SEA is reflected in its zero-tolerance policy for SEA among staff and implementing partners. To fulfill this commitment, the AAPSM is seeking to build the Agency's internal capacity and knowledge to respond to SEA allegations efficiently and effectively. This includes the development of a comprehensive Protection from Sexual Exploitation and Abuse policy that is currently in process. The Bureau for Management (M) was tasked with conducting a business process review (BPR) to assess the Agency's ability to respond to SEA allegations, create a standard process for Agency response to SEA allegations, and offer recommendations to implement change and improvements. The BPR's desired outcome is a set of recommendations that will improve the Agency's capacity to respond to and manage SEA allegations in several ways, including ensuring sufficient Agency action has been taken by improving standardization and coordination, increasing trust in the Agency's reporting mechanisms, and reducing Agency strategic, programmatic, and reputational risk related to SEA. The BPR identified several key issues related to the Agency's response to SEA allegations, including the need for a single operating unit to coordinate Agency resolution of SEA cases, the need to consolidate safeguarding policies, and the need for a comprehensive operating policy with clear standards, operating procedures, and roles and responsibilities for the review of and response to SEA allegations and case management. The BPR made several recommendations to address these issues, including designating or establishing a single operating unit to coordinate Agency resolution of SEA cases, consolidating safeguarding policies, and developing a comprehensive operating policy. The BPR also recommended that the Agency procure a dedicated Case Management System (CMS) to support a coordinated, streamlined, and consistent response to all SEA allegations and cases. In addition, the BPR recommended that the Agency develop a plan for accepting investigative materials directly from IPs for consideration of administrative action on substantiated SEA allegations, provide information to IPs about the requisite evidentiary thresholds for suspension and debarment, and gather and disseminate methods and best practices regarding preventing the rehiring of perpetrators of SEA in the development community. The BPR also recommended that the Agency pursue a Memorandum of Understanding (MOU) with the Office of Inspector General, Office of Investigations to establish guidelines and processes for coordination and information sharing for SEA, and for all other forms of misconduct, to the maximum extent practicable. The BPR's recommendations are intended to improve the Agency's capacity to respond to and manage SEA allegations, increase trust in the Agency's reporting mechanisms, and reduce Agency strategic, programmatic, and reputational risk related to SEA.