ICAI policy for reporting sexual exploitation and abuse


This document sets out ICAI’s policy and procedures for reporting concerns around sexual exploitation and abuse whilst undertaking work for ICAI in the UK and overseas. Although its primary focus is on reporting, it is also hoped that it will play a part in preventing unacceptable behaviour. It is intended for use by the ICAI Secretariat, Commissioners and ICAI’s contracted service provider.

In line with the ICAI-DFID Framework Agreement (produced before the establishment of the FCDO), ICAI’s policy and procedures in this area closely follow FCDO’s – ICAI’s sponsoring department – although they have been amended where necessary to reflect ICAI’s particular circumstances and operational independence from government. Investigation of any concerns will be carried out through FCDO channels and, as such, this document has been agreed with FCDO.

ICAI is committed to ensuring the protection of all those who participate in ICAI reviews, and in particular children or vulnerable groups. All suspicions, allegations or evidence of exploitation and abuse will be taken seriously and reported. ICAI will:

  • Provide effective management of ICAI Secretariat and Commissioners through ongoing training and supervision. All Secretariat staff are required to sign up to FCDO’s standard of conduct and behaviour for staff, and Commissioners are required to adhere to the Code of Conduct for Board Members of Public Bodies which is based on the Seven Principles of Public Life;
  • Have effective complaints and whistleblowing procedures in place and ensure that they are well communicated and accessible for all staff;
  • Ensure staff have access to confidential support should they wish to discuss any issues (e.g. HR / Employee Assistance)
  • Use procedures to investigate fully and take action following any allegations of abuse against staff, contractors or third parties according to FCDO policy;
  • share relevant information with external agencies who need to know about any allegation or evidence of malpractice;
  • ensure all appropriate checks are completed when recruiting staff and contractors; and
  • fully support and protect all permanent and service provider staff who in good faith report concerns.

ICAI has adopted the definition of sexual exploitation and abuse used in the UN Secretary-General’s Bulletin of October 2003. Further details are at Annex A. All staff are trained to ensure awareness of the definitions and in recognising the potential signs of such abuse.

This document replaces all previous policy statements. Last updated August 2021 to update department names following establishment of FCDO.

Reporting concerns

It is your duty to report any suspicions or incidences of sexual exploitation or abuse. Reporting can be as simple as writing a short email or asking to speak to someone about your concerns. Don’t worry if you are not sure if you want to report something – it is better to check rather than leave something unreported.

Action for ICAI secretariat and commissioners

All staff and Commissioners should follow the procedures below to ensure that all allegations or suspicions of sexual exploitation or abuse are reported. Reports of concerns raised during the evidence gathering phase of reviews should follow the protocol at annex B.  Any instances raised by the Supplier are logged at the monthly contract performance meeting and ICAI secretariat will log instances in the monthly and quarterly business updates to ICAI Commissioners. Details of cases will remain confidential.

If you feel you can, speak to your line manager or Head of Secretariat in the first instance. If you do not feel it is something you can discuss with your line manager or management chain:

  • reportingconcerns@fcdo.gov.uk
  • or phone +44 1355 843747

If you want to have a confidential discussion before reporting a concern, the Employee Assistance Programme (EAP) offers counselling and support. This service is confidential, and any information provided is not accessible by anyone at ICAI or FCDO.

Action for service provider

ICAI service providers are bound by FCDO’s Supply Partner Code of Conduct.

In addition to value for money, the Code sets out expectations and obligations on safeguarding, ethical behaviour, respect for human rights and corporate social responsibility. It specifically requires suppliers to apply and adopt safeguarding policies, and also to abide by the principles of the UN Global Compact, which calls on businesses to ensure they are not complicit in human rights abuses, or forms of exploitative labour, including child labour.

The Code requires suppliers to train their staff regularly in ethical behaviours and for a workforce whistleblowing hotline to be provided and the associated policies to be publicised throughout the suppliers’ supply chain. FCDO’s training and compliance monitoring regime will clearly spell out the requirement for a zero-tolerance approach to sexual exploitation and abuse within supplier organisations and down their tiered delivery chains.

Service provider staff should also report any concerns they become aware of to reportingconcerns@fcdo.gov.uk and inform the Head of Secretariat.


All disclosures will be treated in a sensitive and, where possible, confidential manner. If required, the identity of the individual making the disclosure will be kept confidential to the extent possible once an investigation process starts. We will ensure staff are protected if raising concerns with us.

Disciplinary action will be taken if staff attempt to victimise or retaliate against someone who raises a concern, if a malicious concern is raised (i.e. deliberately falsifying a concern) or if individuals do not support any investigation (e.g. by breaching confidentiality).

Annex A: Standards of behavior while working with ICAI

The following behaviours are prohibited.

  • sexual abuse – including sexual assault or acts to which the individual did not, or could not, consent
  • sexual activity with children (persons under the age of 18) regardless of the age of majority or age of consent locally. Mistaken belief in the age of a child is not a defence;
  • exchange of money, employment, goods or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour. This includes any exchange of assistance that is due to beneficiaries of assistance;
  • sexual relationships between ICAI Commissioners, Secretariat staff or contractors and beneficiaries of assistance, since they are based on inherently unequal power dynamics and undermine the credibility and integrity of the work of ICAI;

The standards set out above are not intended to be an exhaustive list. Other types of sexually exploitive or sexually abusive behaviour may be grounds for disciplinary measures.

Annex B: Protocol for reporting SEA concerns during evidence gathering for reviews 

ICAI is committed to playing a full and active role in preventing sexual exploitation and abuse, and in reporting any concerns transparently.

In addition to its own corporate policy and procedures for reporting sexual exploitation and abuse, ICAI also has an obligation to address concerns or allegations that come to light as it gathers evidence for its reviews.

When such concerns are raised ICAI will report them to the UK government department with primary responsibility for funding the organisation to which, or individual to whom, the concerns relate. This correspondence will be shared with FCDO.

Where there is no clearly responsible UK government department, ICAI will report the concerns to FCDO.

In either event, ICAI will record and report the concern [either in a thematic review or annual report] including any action on the part of the responsible authority, anonymised where necessary to respect the principles of confidentiality and individuals’ personal data.