WORKING WITH DG ECHO AS AN NGO PARTNER | 2021 - 2027
SEAH - YEARLY REPORTING ON ALLEGATIONS - NGO
ECHO partners have to report allegations:
- In which the alleged perpetrator is an affiliate of DG ECHO partner or one of their implementing partners or contractors AND
- In which the victim/survivor is either a beneficiary of a DG ECHO grant or an affiliate AND
- The incident occurred in the framework of the implementation of a DG ECHO grant.
These three conditions have to be met at the same time.
DG ECHO decided to narrow the scope of the reporting and focus on the implementation of DG ECHO grants.
The information collected will be used to improve DG'ECHO's risk assessment and we need a specific focus on ECHO-funded operations, also considering that SEAH reporting is becoming more and more the norm among donors and we will reduce this way cases that are reported multiple times to different donors.
Bearing in mind that there is a duty to protect the beneficiaries as they are in the most vulnerable situation, the objective of the exercise is to get a picture of ECHO operations.
Partner organisation are bound to the "do no harm" principle (see art. 4.4 of the Humanitarian Partnership Certificate), which protects members of the local communities where the partner operates.
Applying a victim/survivor-centered approach is essential when dealing with SEAH allegations, especially when dealing directly with victims/survivors.
ECHO applies a survivor-centred approach and expects its partner to do so when dealing with SEAH allegations (as also checked in the ex ante assessment). The annual reporting is only one tool in our PSEAH work and is meant to inform DG ECHO about the reality on the ground.
If a case is systematic, affects the PSEAH system of the partner organisation and puts into question the ex-ante assessment, the partner has to report it individually, regardless the link with DG ECHO. Section IV of the Guidance note provides additional information on which cases need to be reported individually to DG ECHO.
If the case is isolated, and fits the definition in the Guidance note, the partner needs to report it in the annual report only, because we need cases directly related to ECHO operations.
If case does not fit the definition in the guidance note and, at the same time, is not systematic, partners can decide to report it to DG ECHO.
Yes, ECHO partners are requested to report on allegations of sexual harassment. Please refer to Section A.7 of the reporting form.
Article 5.3 of the Humanitarian Partnership certificate requires partners to provide with "an annual reporting to the Commission on the implementation of its policy related to sexual exploitation, abuse, harassment and other types of unethical behaviour [...]".
Please note that staff-to-staff harassment has to be included in the report when it occurs in the framework of an ECHO project (see answer to question n. 1).
The number of allegations refers to the cases that were brought to your attention during the reporting period, regardless of when the incident has taken place.
DG ECHO requests partners to report allegations that occurred from the operational start date until when the final payment is received.
One of the three conditions for partners to report an allegation is that the incident occurred in the framework of the implementation of a DG ECHO grant. DG ECHO expects that the incidents reported happened in countries where ECHO has operations or in countries where the HQ of the partner organisation are based.
Partners are requested to report allegations that are not linked to the implementation of a DG ECHO grant only if they fall in the category under Section IV of the Guidance note on the yearly reporting of SEAH allegations, published in DG ECHO partners’ website.
ECHO asks to report these cases as soon as possible, even if not related to an ECHO grant for the following reasons:
- They are a sign for a systemic risk (e.g. if management is involved or if the situation has not been detected for a long time) and hence could present a threat for other beneficiaries etc. in ECHO projects as well.
- They risk resulting in media attention and the Commission might receive questions either from journalists or also from the budgetary authority (Council and European Parliament). ECHO therefore needs to be informed immediately in order to provide timely and consistent replies.
- A sensitive case creates a high reputational risk for the certified partner and, by extension, for DG ECHO as signatory of the certificate, which attests among other things that the partner has an effective PSEAH framework in place.
When the implementing partner/co-partner is also an ECHO partner, it has to report on the SEAH cases that have happened in the implementation of the grant and that meet the other conditions for reporting and inform the signatory of the ECHO grant that it has reported the case to ECHO.
When the implementing partner is not an ECHO partner, it is for the signatory of the grant agreement with ECHO to report the case.
This rule applies also to NGOs that are members of a federation.
In the case of a consortium, reporting is done per partner, meaning that it is not for the lead partner to report, but for each partner of ECHO, and to coordinate with the lead partner to avoid duplications. The lead partner reports for members of the consortium that are not ECHO certified partners.
Partners that have received the certificate in Q3 of 2023 and have not implemented ECHO grants between award of the certificate and the end of the reporting period are not required to submit the report. However, DG ECHO would appreciate to receive a written communication.
If, before being awarded the Humanitarian Partnership Certificate, the organisation was an implementing partner, it is for the lead partner to report the cases that were recorded in the implementation of the ECHO grant.
For policy non-compliance, partners can refer to situations when a staff member, contractor or volunteer failed to comply with the organisation's policies (such as HR policy related to SEAH issues, e.g. a manager failing to report a SEAH allegation).
Therefore, the scope of application of the definition is larger and, in this case, we ask partners to report them whenever they occur in the implementation of an ECHO grant (alleged perpetrator working under and ECHO grant and/or victim/survivor is a beneficiary of an ECHO grant).
Allegations that fall under the category of “other unethical behaviours” often do not have a single perpetrator or a single victim/survivor, and they can affect a whole community.
Therefore, the scope of application of the definition is larger and, in this case, we ask partners to report them whenever they occur in the implementation of an ECHO grant (alleged perpetrator working under and ECHO grant and/or victim/survivor is a beneficiary of an ECHO grant).
DG ECHO is aware that criminal record checks are not possible in some countries, for a number of reasons. Partners are invited to mark "to a certain extent" if this procedure is a standard where and when possible but not implemented where and when not possible.
Information provided in Section D only refer to the partner organisation, irrespective of their relationship with the ECHO grant.
All partners, including those that have not implemented ECHO grants in 2022, are required to fill Section D.
Section D does not apply to Implementing Partners.
Organisation representatives are persons who are not regular staff of the partner organisation, but are identified as representing the organisation, e.g. Board Members (if not staff) or prominent figures who serve as ambassadors of the organisation.
The information allows ECHO to assess the partners’ safeguarding systems on a global level.
It will furthermore allow ECHO to improve its risk assessment and expects that it will be fruitful for the partners as well.
Also, ECHO will share the main outcomes (on aggregated level) with other donors with the objective to learn from each other and in the long term improve PSEAH systems on a global level (beyond DG ECHO). DG ECHO is also considering to exchange part of the findings of the report with VOICE HP Group.
After the first round of reporting, ECHO will carry out an analysis of this report and enter into a dialogue with the partners.
ECHO will file the information in a protected folder with an extremely restricted access.
When the data will be processed for aggregation, the name of the partners will be anonymised.
We let the partner organisation to take the decision, based on the internal procedures.
We ask for that piece of information in order to speed up communications about PSEAH-related matters.
You can find DG ECHO's definition of sexual harassment at page 9 of the Guidance note.
“The term “sexual harassment” means any form of unwanted verbal, non-verbal or physical conduct of a sexual nature with the purpose or effect of violating the dignity of a person, in particular when creating an intimidating, hostile, degrading, humiliating or offensive environment.”
It involves any unwelcome sexual advance; request for sexual favours; verbal or physical conduct or gestures of a sexual nature; or any other behaviour of a sexual nature that might reasonably be expected, or be perceived, to cause offence or humiliation to another, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment.
For policy non-compliance, partners can refer to situations when a staff member, contractor or volunteer failed to comply with the organisation's policies (such as HR policy related to SEAH issues, e.g. a manager failing to report a SEAH allegation).
For "other unethical behaviours" DG ECHO means forms of abuse, harassment and other forms of misconduct not of sexual nature. Partners can also refer to article 4.9 of the Certificate: “discrimination, forced and child labour, modern slavery, exploitative practices towards staff, partners, contractors or beneficiaries, illegal employment and intentional environmental damage”.
Finally, fraud cases have to be reported separately to echo-reportfraud@ec.europa.eu by filling in the Fraud Allegation Reporting Form.
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The Guidance document is available in ECHO partners' website under "Humanitarian Certificate 2021-2027".
The reporting form was previously shared with partners when this year's reporting exercise was announced.
Please send an e-mail to echo-reportmisconduct@ec.europa.eu if you have not received it.
Please add this information to the reporting form (last point) and send it to echo-reportmisconduct@ec.europa.eu. In APPEL there is no field foreseen for this information.
The report has to be submitted by email to ECHO-REPORTMISOCNDUCT@ec.europa.eu by 30 April every year.
Regarding your questions on how to improve the awareness, ECHO is working together with other donors to find solutions. You are invited to send us proposals what DG ECHO can do in this respect: echo-reportmisconduct@ec.europa.eu
If you have submitted the report before the deadline and you would like to replace it with a new version, you can do so until 30 April. In that case, please indicate in the subject line clearly that this version is to replace an already submitted report and we will delete the first report. After 30 April, we would need to assess on a case-by-case basis.
As soon as the Partner becomes aware of any corrupt, fraudulent, collusive or coercive practice potentially impacting an ECHO funded action, it has to inform immediately DG ECHO by filling in the fraud allegation reporting form published on the ECHO Partners’ Website and sending it to echo-reportfraud@ec.europa.eu.
The annual report focuses on the implementation of DG ECHO grants, therefore partners do not have to report allegations that happened in the framework of the implementation of projects that are not funded by DG ECHO.
If the staff’s salary is (partially) funded by DG ECHO, it is considered as an affiliate of a DG ECHO partner and needs to be included.
ECHO partners have to submit one single report covering the allegations received in the framework of the implementation of ECHO-funded actions worldwide and meeting the three criteria listed in FAQ 188.
Please refer to DG ECHO partners' website https://www.dgecho-partners-helpdesk.eu/ngo/partners-co-partners-and-implementing-partners
At this stage, it is not possible to differentiate which allegations were reported by the beneficiary of the ECHO grant and the local partners, which are not certified. DG ECHO will consider modifying the reporting template in order to capture this piece of information.
In section A, partners have to report the number of new allegations (meaning the cases that were reported in 2023, regardless of when the incident has taken place).
In section B, partners have to report about new allegations and allegations carried over from previous year(s) (meaning cases reported before 2023, but that were still open in 2023).
Partners have to fill section A.2 of the template "Allegations per country", by opening the relevant sheet in the form. Then, partners can report the number of allegations by country.
The purpose of question A.4 is to collect data about the reporting channels and type of informer who reported the allegation. The purpose of question A.5 is to collect information about the victims/survivors, namely their status, their gender and their age.
Board Members are considered as "Staff member (management)".
Carry overs are cases that were reported to the partner before 2023, but that were still open in 2023, including because the investigation is still ongoing.
To answer question B.1, please report the number of cases that were closed after a preliminary review (i.e.: you decided not to launch in investigation after the preliminary review).
To answer question B.2, please report the number of cases for which an investigation was launched after the preliminary review.
There is no distinction between investigations conducted by the partner or by the implementing partner. DG ECHO is interested in knowing how many allegations were followed by an investigation.
Section D "Prevention" applies only to ECHO partners, irrespective of their relationship with ECHO grants (i.e.: including staff whose salary is not paid with ECHO funds).
The data collected in section D "Prevention" have the purpose to provide a picture of preventive measures in place within the organisation. This is why all ECHO partners are requested to fill it, even if they have not implemented ECHO grants in the reporting year.
The MDS has the objective of ensuring that perpetrators of sexual misconduct are not moving between organisations undetected, thanks to reference checking. Additional information is available at https://misconduct-disclosure-scheme.org.
Although not mandatory, ECHO encourages signing up for the MDS as well as for the UN Clear Check database for UN bodies and we consider it to be good practice in terms of PSEAH.
Although not mandatory, ECHO encourages signing up for the MDS, and we consider it to be good practice in terms of PSEAH.
DG ECHO is aware that, in some Member States, partners cannot join the MDS because of national labour law or data protection law, and we are interested in knowing more.
An "affiliate" is a person who is hired or engaged by the partner (e.g.: staff members, contractors, volunteers, incentive workers).
Please contact echo-reportmisconduct@ec.europa.eu.
