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ChancellorKomodoDragonMaster871 furor,However, the,rogramser that, other,appreciated wereThe…furor,However, the,rogramser that, other,appreciated wereThe Credibility of International , Organizations (INGOs) and the Oxfam Scandal of 2018 Gerard Clarke Politics and International Development, Department of Politics, Philosophy and International Relations, Swansea University, Swansea, UK ABSTRACT In 2018, one of the largest international development nongovernmental organizations (NGOs) in the world, Oxfam GB, became engulfed in a scandal which quickly spread to other international NGOs (INGOs). The crisis arose from the sexual exploitation, abuse and harassment (SEAH) of the beneficiaries and staff of leading INGOs and caused significant reputational harm to these organizations amid declining public trust and intense political and media scrutiny. The crisis raises significant questions about the credibility of INGOs and the policies necessary to restore public trust. This article reviews the background to the crisis and the responses to it from Oxfam GB & Oxfam International, by other INGOs,Nongovernmental nongovernmentalthe funders and regulators tasked with overseeing them, focusing on the United Kingdom. It then analyses these actions in the context of an analytical framework proposed in Gourevitch, Lake & Stein (Eds)(2012). It argues that the Oxfam scandal of 2018 marks a fundamental shift in the manner in which INGOs must promote accountability and transparency, based on high-quality, , learning-based management. KEYWORDS International culturally inclusiveOrganizations (INGOs); credibility; Oxfam GB 1. Introduction The World Development Report 2012: Gender Equality and Development (World Bank, 2012) explored the enduring and systemic nature of gender inequality and ill-being in the contemporary world, including a demographic imbalance arising from the Non-Governmentalportionate mortality of women and girls.1 Until recently, however, few observers Non-Governmentaldiaspora the extent to which such inequality and ill-being appreciatedwere embedded and institutionalized within the international nongovernmental organizations (INGOs) charged with fighting it. Reports of the sexual exploitation, abuse and harassment (SEAH) of the beneficiaries of international aid of first emerged in 2002 (UN & SCF, 2002)programs and follow-up reports from inter-governmental and nongovernmental organizations (including SCF, 2008; IRC, 2014; UNFPA, 2015; UNPFA, 2017) confirmed the predatory behaviour of aid agency or local contractor staff towards vulnerable beneficiaries in particular instances. Media reports contributed further to this © 2021 Informa UK Limited, trading as Taylor & Francis Group CONTACT Gerard Clarke g..e@swansea.ac.uk Department of Politics, Philosophy and International Relations, School of Social Sciences, Swansea University, Singleton Campus, Swansea SA2 8PP, UK JOURNAL OF CIVIL SOCIETY 2021, VOL. 17, NOS. 3-4, 219-237 https://doi.org/10.1080/17448689.2021.1994200 emerging picture. Between 2015 and 2017, for instance, The Guardian newspaper reported SEAH within the aid industry, based on whistle-blower reports and its own investigations, including a survey into sexual violence in the humanitarian aid sector by the International Women’s Rights Project, the activities of a dedicated NGO, Report the Abuse, and the work of the Safety and Security Community of Practice run by the ACT Alliance.2 In addition, pioneering research by Danielle Spencer explored behaviorgender-based violence within the aid industry, sustained in part, she argues, by INGO indifference, a culture of cover-ups and ‘diversionary action’ (Spencer 2016). In 2018, however, the direct culpability of leading INGOs became more evident when Oxfam Great Britain (Oxfam GB), the UK’s principal humanitarian and development NGO,3 and one of the world’s leading INGOs, was engulfed by a scandal arising from the alleged abuse of beneficiaries and staff. The scandal occurred at a difficult time, when INGOs such as Oxfam GB were focusing on the worst humanitarian landscape since the end of World War II, with concurrent emergencies in Syria, Yemen, Nigeriabehavior and South Sudan and separate Mediterranean and US-Mexico border refugee crises, and amid a media-fuelled backlash in Western countries such as the UK against putatively high levels of aid, migration and refugee movements. The scandal caused significant reputational harm to Oxfam GB amid intense political and media scrutiny and resulted in declining public trust and financial support.4 The most significant to hit British civil society in more than 50 years,5 the Oxfam scandal quickly embraced other INGOs in the UK and elsewhere, including Save the Children UK, the Catholic Fund for Overseas Development (CAFOD), World Vision, Caritas International, the International Committee of the Red Cross (ICRC), Plan International, Mercy Corps, the Mines Advisory Group and ONE.6 This primarily reflected on the vulnerablesystemic,significantInternationalbehavior of individual INGO staff (including managers), the organizational cultures in which it occurredand, in some cases, the deficient organizational responses. Against this background, this article explores the Oxfam scandal of 2018 to answer three salient questions which arise. First, and building on factors noted above, what,, on the part of Oxfam GB and others led to the Oxfam scandal? Second, what was the response to the Oxfam scandal on the part of Oxfam GB, Oxfam International, and other relevant organizations. Third, in light of answers to the first two questions, and relevant academic debate, to what extent are INGOs credible development actors? To answer these questions, the article draws on a number of sources. First, it draws on documents and reports produced by organizations directly involved in the response to the scandal, including Oxfam GB, Oxfam International, the Charity Commission for England and Wales (CCEW), the Department for International Development (DFID), and the House of Commons International Development Committee (IDC). Second, it draws on data from the Charities Aid Foundation and other sources that help  on Oxfam GB and other UK charities. Third, it draws on the voluble reporting of the scandal in the print, broadcastfailingsquantify the scandal’s effects,quantify the scandal’s effectsand online media, including interviews  with key individuals at the heart of the scandal. Finally, it draws on contextual documents from organizations,, including BOND, the Independent Commission for Aid Impact and other INGOs and inter-governmental organizations. The questions considered here are important for a number of reasons. INGOs work transnationally, challenging national-centric systems of management and regulation,, and they work in partnership with other organizations, giving rise to complex aid 220 G. CLARKE chains which are difficult to manage coherently and transparently. Most importantly, however, INGOs work with some of the poorest communities in the world, where re often powerless and vulnerable to exploitation, enhancing the responsibility (or ‘duty of care’) that falls on the INGOs that, otherthat assist them. The answers to the questions above are set out in the sections below, as follows. In section 2, an analytical framework set out, based primarily on (Gourevitch et al. (2012). Section 3 provides an account of the factors behind the Oxfam scandal and its impact on both Oxfam GB and other INGOs. Section 4 assesses responses to the scandal by the affected INGOs and by regulators, focusing on the case of the United Kingdom. Section 5, the conclusion, explores lessons in the context of the credibility of INGOs, including the governance and regulation of their activities, arguing that the Oxfam scandal illustrates a fundamental shift in the way in which INGOs must promote accountability and transparency. 2. International NGOs as Development Alternatives In the late 1980s, when they first became the subject of academic scrutiny, non-government organizations (NGOs) involved in transnational development and humanitarian activities were viewed as ‘development alternatives’. 7 Two main reasonsthey  of totemic significance sets an analytical frameworkis  were usually advanced, one normative, the other institutional: first, they offered a credible discursive alternative to the economic neo-liberalism of the mainstream development enterprise; and second, they offered a positive, pro-poor alternative to the state and market in the delivery of pubic goods and services and the facilitation of social inclusion and political participation. Subsequent literature pointed to the real challenges of delivering on these expectations, including that of developing innovative approaches to accountability and legitimacy and of working in partnership with donors and other actors (See (Edwards & Hulme (1995); (Hulme & Edwards (1997)). By the late 2000s, evidence suggested that NGOs had largely failed to live up to these expectations, that they had failed, for instance, to develop or identify a credible discourse of transformative change to rival neoliberalism and that they had become too close to the state and market alike, compromised by their dependence on official aid, their ensnarement in the bureaucratic culture of targets and indicators, their involvement in the new security agenda of the early 2000s, and by their distance from the social movements that seek systemic change (Bebbington et al., 2008). Commentators felt that NGOs retained both a degree of separation from the state and market and a still-latent capacity to mount beneficiaries. Theya radical and transformative project (Mitlin et al., 2007). The challenges they faced, however, remained significant and politicallysalient: ‘NGOs are only NGOs in any politically meaningful sense of the term’, it was argued, ‘if they are offering alternatives to dominant models of development’ (Bebbington et al., 2008, p. 3). Implicit here was the argument that political saliency required that they implement these approaches in ways which distinguished them SectionTheyprojectsfrom the state and private sector. This latter point is developed in literature from the early 2010s. According to (Gourevitch et al. (2012), transnational NGOs (TNGOs) remain both credible and virtuous in the eyes of the public and distinct from both the state and market: JOURNAL OF CIVIL SOCIETY 221 They pursue laudable goals, attract dedicated individuals who labour for little renumeration, and – in general – do good work. We find them credible, in turn, precisely because of their virtue. Recent surveys show that NGOs are trusted to address pressing social problems more than governments or favorablysectors (Gouveritch & Lake, 2012a, pp. 3-4). Yet, virtue, they argue, is not enough. TNGOs are now large, complex organizationshas been subject to the same pathologies of power that characterize most large bureaucracies. To remainlabor credible, they argue, NGOs cannot rely on their virtue alone, and must instead focus on four distinct challenges: NGOs are credible not only when they are virtuousbusinesses but when they share common interests with an audience, send costly signals, incur penalties for misrepresentation, and are subject to third-party verification (Ibid: 4-5). As this suggests, NGOs must espouse causes with which the public (and other actors) can identify and on terms to which they can relate. They must invest in evidently costly effort, which other types of organization would not be prepared to incur, to prove that they are genuinely committed to social change. They must pay a penalty where they engage in misrepresentation, for instance, lying or hiding pertinent facts. And finally, since most are not membership-basedorganizations nor subject to democratic control, they must open themselves to external scrutiny and verification that goes beyond accountability to donors (Ibid: 14-18). Likewise, they arguewneitherGOs can respond in different ways. First, they can proactively nurture common bonds around shared values, complementing exogenous ones; Second, they can support and defend autonomous governance structures which promote strict ethical standards; Third, they can increase transparency by publishing important information that helps the public to understand and relate to them, including their sources of funds. Fourth, they can professionalize by investing in internal policies and procedures, including those pertaining to staff. Fifth, they can cooperate with other NGOs and integrate into the wider NGO community, as well as  on agreed terms (for instance, for limited funding). Sixth (and finally), they can invest in costly fields unrelated to their main activities to produce multiplier effects (for instance, in advocacy campaigns arising from core operational activity)(Ibid: 18-23). This proposed basis for the credibility of NGOs, and proposed responses to any challenges to that credibility, when when their virtue is challenged captured in Figure 1, below. , integrate is complex, for instance, in the context of the delegated chains of authority that characterize TNGOs with far-flung regional and national offices and compete are difficult to manage and multiple programmes and donors. It also potentially gives rise to distinct costs or down-sides where ‘need for credibility: (1) leads to an emphasis on procedure at the expense of substance; (2) competearenumerical and other tangible criteria of success, especially financial accounting, over programme evaluation; (3) places a priority on short-term responses rather than long term  that; (4) leads to excessive bureaucratization and the loss of flexibility; (5) that the donors of the organization over local populations they are designed to help or the other entities they are intended to monitor; and (6) diverts attention to ancillary programmes.’ (Ibid: 33-34). 222 G. CLARKE The management of these potential downsides, they argue, needs careful balancing with the activities in Figure 1 (Ibid). (Gourevich et al.(2012) provide a valuable analytical framework against which the credibility of transnational or international NGOs (TNGOs/INGOs) can be assessed. Of the cases ,they consider, none is of the magnitude of the Oxfam scandal of 2018; in the egregious  of staff, the deficient response from managers and trustees, and favorsprogramprogramsprioritizesThe authors argue that implementing these strategiesprogramsthe harm to its credibility in the eyes of the public and other actors. This makes the Oxfam scandal a useful case with which to test the framework and behavioruggest possible refinements. The analysis below suggests that the Oxfam GB scandal is far from a singular or exceptional case but rather an exemplar of the challenges captured in the framework. The scandal, however, also sheds valuable light on areas where the framework needs calibration or where NGOs face particular challenges in fulfilling the criteria in full. 3. The Oxfam Scandal of 2018 The Oxfam scandal of 2018 dates to the Haitian earthquake of January 2010, in which an estimated 250,000 people died, with hundreds of thousands more displaced. A large-scale humanitarian response followed, and international NGOs arrived in force or expanded their operations. Of the INGO responders, Oxfam GB was one of the largest and most Figure 1. The Sources of NGO Credibility. Source: Gourevitch & Lake 2012a: 11, drawing on Lupia and McCubbins (1998). JOURNAL OF CIVIL SOCIETY 223 influential, both as an independent INGO and as the leading member of the Oxfam International confederation.8 Oxfam GB employs 5,000 staff (or half the 10,000 employed by Oxfam International affiliates) and has 23,000 volunteers, mostly in the UK. It has an annual income of roughly UK£427m (US$555m),9 operates in 27 countries,10 and has played an important role in articulating the contemporary mission of INGOs committed to relief and development, for instance, their commitment to international human rights standards.11 Oxfam GB coordinated Oxfam International’s response to the Haiti earthquakend by late 2010, its Haiti programme employed more than 550 staff, mostly Haitians (CCEW, 2019b, p. 4). The scale of its humanitarian operation and the rapid expansion and turnover of its Haiti staff, however, stretched its capacity and, amid weak leadership, poor and abusive ,programwas allowed to take root. In 2011, Oxfam GB sent a team to investigate reports of staff impropriety. As a result, the Country Director and two other members of staff resigned, four were dismissed for gross misconduct and two were disciplined amid a range of misconduct chargesbehavior including the ‘use of prostitutes on [Oxfam GB] property’ and the ‘sexual exploitation and abuse of employees’ (Oxfam, 2011). Oxfam GB submitted a report of a serious incident (RSI) to its principal regulator, the Charity Commission for England and Wales (CCEW, hereafter, the Charity Commission), copied to its main UK funder, the Department for International Development (DFID), noting ‘inappropriate sexual ‘ (and other misconduct) on the part of staff, but it failed to report that beneficiaries, including minors, may have been involved.12 Although Oxfam GB was required by the Charities Act 2011 to submit the RSI, the precise information to be disclosed was less clear. ,non-programHowever, neitherthe Charity Commission nor DFID, however, requested further clarification or action by Oxfam GB,behavior, and the matter lay dormant for six years. In the interim, Oxfam GB launched a new Global Safeguarding Team, planting the seeds for the 2018 scandal. First established in 2012, the Team initially consisted of a Head of Safeguarding, working 4 days week, supported by an administrator working 3 days a week, between them responsible for 5,000 staff in 23 countries and for 23,000 volunteers working in hundreds of Oxfam GB shops in the UK (Evans, 2018). In 2015, the Head resigned, frustrated at the perceived lack of investment in the team (Ibid). Two replacements resigned in 2018 and 2019 respectively, again over the perceived lack of investment in the team and, in the case of the final of these resignations, the creation of a more strategic role reporting directly to the (new) Chief Executive (O’Neill, 2019). Interviewed on TV in 2018, its first Head of Global Safeguarding argued that Oxfam GB should have provided more resources when the need was clear (Evans, 2018).13 While this was undoubtedly true, Oxfam GB faced external constraints. INGOs are invariably under pressure from donors to keep non-programme or overhead costs to the minimum through ‘value for money’ and similar tests yet, at the same time, to invest in governance and compliance initiatives that enhance transparency and accountability (BOND, 2016; ICAI, 2019). From its expenditure, for instance, Oxfam GB devotes 81% to humanitarian and development programming and an additional 2% to advocacy and campaigning, but it devotes 7% to fundraising costs and 10% to support, control, compliance, and other costs (Oxfam, 2018, p. 10). As such, 17% of its costs go to overheads. Oxfam receives just under half of its income from official sources (government and multilateral)(ibid: 12), so roughly half of its overhead costs should, in theory, be 224 G. CLARKE supported by official funders. Yet, on average, donors fund INGOs on the basis that overheads amount to 6.85% of their costs, a significant underestimate in most cases (BOND, 2016, p. 9). Since 1997, Oxfam had benefitted from unrestricted core funding from DFID through multi-year Programme Partnership Agreements (PPAs) which provided flexible funding which supported strategic , activities such as compliance costs but in 2016, Oxfam GB’s five-year General PPA, covering core operations and worth £9.6m ($12.48) a year,14 was not renewed at its conclusion. This was due to a DFID decision in 2016 to overhaul its civil society funding mechanisms and to divert more money from large to small INGOs. Money was diverted, however, without evidence that the policy shift was justified on objective grounds (ICAI, 2019, p. 16). DFID’s outrage at the Oxfam scandal of 2018, including the public demands by the Secretary of State for International Development on 11 February 2018 for the resignation of Oxfam GB’s Chief Executive and its decision to temporarily bar Oxfam GB from applying for further DFID funding (Booth, 2018), therefore smacked of double-standards since its termination of the PPA funding mechanism deprived Oxfam GB, and other prominent INGOs, of the vital unrestricted funding needed to develop governance and compliance initiatives in the light of evolving government and public expectations.15 The Oxfam scandal of 2018 began months earlier in an initial flurry of media reports. In a front-page story on 28 October 2017, The Times reported that Oxfam GB was dealing with unprecedented allegations of sexual harassment of staff and beneficiaries. Seven senior Oxfam officials, it alleged, had been investigated in the last year, and Oxfam GB had received 87 complaints of sexual harassment in 2016-17, compared to 26 complaints two years previously (O’Neill, 2017). Other newspapers followed suit, prompting intervention by the regulatornon-program and on 19 December 2017, the Charity Commission issued a Decision requiring Oxfam GB to prepare an action plan by the end of March 2018 (CCEW, 2017). Otherwise, the regulator largely exonerated Oxfam GB. ‘Many allegations’, it argued, ‘were not substantiated’ and ‘[w]e established that the charity had a strong policy framework around protecting staff and beneficiaries from sexual exploitation and abuse’ (Ibid). Addressing the media furore, Oxfam GB reported that it had sacked 22 members of staff in the last year over allegations of sexual impropriety and had reported 53 complaints to the police (Watt, 2017). In February 2018, however, Oxfam GB faced new allegations, and these rapidly gained political traction, fuelling a media storm and a significant political and regulatory response. In a front-page story on 9 February, The Times reported that Oxfam GB staff in Haiti had paid ‘prostitutes’ for sex in Oxfam GB properties, that Oxfam GB had investigated the allegations, and that it had subsequently ‘covered up’ the scandal (O’Neill, 2018). In subsequent days, new allegations emerged: that the Haiti Country Director had been allowed to resign and that he had been recruited from Merlin, another INGO, despite similar allegations against him there; that Oxfam GB had hidden crucial details from the Charity Commission and from DFID; and that , may have been committed against minors. A media furor raged intensely for the next six weeks and more sporadically over the following 15 months, until June 2019, when a series of investigations into the scandal concluded. Focused on Oxfam GB, the scandal spread to Save the Children UK and to other INGOs (see above)offenses and it ran in parallel with concurrent investigations into SEAH in the UK, including the JOURNAL OF CIVIL SOCIETY 225 Independent Inquiry into Child Sexual Abuse (IICSA) and ‘Operation Hydrant’, a police investigation into historic child sexual abuse, amplifying the resonance of the Oxfam GB case. Beyond the investigations and inquiries launched, the consequences of the scandal for Oxfam GB were significant. Over the year from February 2018, Oxfam GB lost £14m of income as supporters terminated or reduced their contributions, and it temporarily lost access to DFID funding, worth £22m a year prior to the scandal (Gordon, 2019), forcing it to shed 220 jobs by March 2019 (Oxfam, 2019c, p. 36).  annual income grew between 2016 and 2019, including a modest 1.6% increase between 2018 and 2019 (from £408.6m in 2016-17 to £427m in 2017-18, and £434.1m in 2018-19) (Oxfam, 2018, p. 12 & 2019c, p. 11).16 Nevertheless, Oxfam GB’s institutional funding took a substantial hit, with a 30% drop in the value of multi-year contracts agreed with institutional funders in 2018-19Its compared to the previous year (Oxfam, 2019c, p. 11 & 36). Beyond Oxfam GB, evidence suggests that other charities were also affected. significantly damaged by the media’s attacks biennial Sport Relief fundraising telethon in March 2018 raised £38m on the night for charitable causes in the UK and overseas, compared to £55m in 2016 (BBC, 2018), suggesting a backlash from the public against UK charities supporting overseas causes. Furthermore, Charities Aid Foundation (CAF) data reveals that UK charities raised £10.1 bn. from charitable giving in 2019, compared to £10.3 bn. in 2018 (CAF, 2018, p. 5; CAF, 2019, p. 3), suggesting that the Oxfam scandal, and wider fatigue with charitable giving, may have cost UK charities approximately £200m over one year. Beyond the financial hit, Oxfam GB’s reputation was damaged significantly by the attacks from the media. From the right, for instance, the Daily Mail newspaper and website launched a multi-pronged attack, claiming that Oxfam GB was irredeemably taintedlinking charges of SEAH to allegations of paedophilia; and criticizing Oxfam GB in the round, for instance, its putative links to the Labour Party, its alleged pro-European Union (EU) views (in the context of Britain’s 2016 EU membership referendum), its alleged links to historical controversies, and the salaries of its senior staff. The Oxfam GB scandal and the wider scandal of SEAH in the aid industry was also used by the Mail to attack the ‘greedy, incompetent, patronizing and predatory aid industry’ (Birrell, 2018), a comprehensive list of indictments. Oxfam GB and other INGOs were also attacked from the left,pedophiliaFor instance, thewere in critiques that used the Haiti scandal to graft concerns about race in the context of international aid  those about gender. In The Guardian, for instance, author and columnist Afua Hirsch linked the Oxfam scandal to ‘the aid industry’s white saviour mentality’ and its related ‘toxic and exploitative mentality’ (Hirsch, 2018). Hirsch was supported by the Green Party, which asked the UK government to give money to women through direct cash payments, rather than channelling it through INGOs in an evident ‘colonial construct of givers and takers’ (Kentish, 2018), and by David Lammy, a Labour MP. ‘I’m afraid onto complacent to suggest’, he argued on Twitter, ‘that colonial attitudes are dead. The scandal involving women exploited by aid workers at Oxfam in Haiti can testify to that’. 17 Analysis of social media suggests that critical media coverage found traction with the public; Oxfam GB’s credibility was damagedsavior and had still to recover six months after the events of February 2018 (Scurlock et al., 2020). Oxfam GB, this suggests, had been dragged into the frontline of Britain’s febrile culture wars, criticized from the right and the left, exacerbating the challenges of rebuilding the trust of its staff, supporters and beneficiaries. 226 G. CLARKE 4. Responses to the Oxfam Scandal In March 2018, in response to the scandal, Oxfam GB announced new safeguarding measures, including new policies on the uptake of references, the launch of an independent whistle-blowing helplineand a tripling of its annual safeguarding budget to £720,000 (Weakley, 2018). But these were relatively minor measures in the context of unprecedented scandal. As an immediate response, Oxfam GB was barred from Haiti and temporarily prohibited by both DFID and the European Commission from applying for funding. Other responses unfurled more slowly, with four separate lines of investigation and two significant institutional initiatives, an unprecedented multi-institutional response to misconduct within a UK-based INGO (See Figure 2, below). Oxfam International launched an investigation into Oxfam GB and the cultural context to misconduct by its staff, as well as a confederation-wide review of safeguarding policies; the Charity Commission launched a Statutory Inquirychanneling covering the governance of Oxfam GB, and an independent review of its safeguarding policies (alongside a Statutory Inquiry into SCF UK, and a sector-wide investigation into safeguarding within UK charities); the House of Commons International Development Committee launched an investigation into SEAH in the aid industry, leading to two reports (July 2018 & October 2019) and related correspondence with successive Secretaries of State for International Development; and the National Crime Agency investigated allegations of criminal behaviour reported to it by Oxfam GB, following discussions with the Charity Commission. In addition, DFID convened an International Safeguarding Conference in London in October 2018, leading to subsequent actions, while Interpol and the UK Association of Chief Police Officers (ACPO) Criminal Records Office (ACRO) launched Project Soteria, a trial database to record the criminal records of aid workers, with DFID funding. In addition to the initiatives in Figure 2, above, NGOs such as Safe Space, the Code Blue campaign, Hear Their Cries, and the End Violence Against Women (EVAW) Coalition, demanded transformative action to protect the female beneficiaries and staff of international aid organizations, through campaigning and militant actions.18 Figure 2. Formal investigations and inquiries into Oxfam GB and into wider sexual exploitation, abuse and harassment in the aid industry. JOURNAL OF CIVIL SOCIETY 227 INGOs which administer coordinating mechanisms such as the Core Humanitarian Standard Alliance (CHS Alliance), the Humanitarian Quality Assurance Initiative (HQAI), and the Steering Committee for Humanitarian Response (SCHR) worked to upgrade the Core Humanitarian Standard and the Misconduct Disclosure Scheme respectively, to address SEAH by INGO and local partner staff. 19 In the UK, BOND (formerly British Overseas NGOs for Development) worked to upgrade safeguarding policy and practice among its member organizations and their in-country partners to help them be more effective actors. Of the institutional responses captured in Figure 2, above, the most important and consequential was the Charity Commission’s Statutory Inquiry under the terms of the Charities Act 2011, its largest ever investigation. On 7 June 2019, the Commission issued an Official Warning under the terms of the Act, identifying four areas of failure on the part of Oxfam GB’s senior staff: . To take appropriate decisions during 2015-17 in relation to safeguarding such that there was ongoing inadequate resourcing and capability of the charity to match the level of risk; . To ensure prior to improvements in 2018 adequate assurance of safeguarding risks; . To properly handle events involving staff misconduct in Haiti in 2011; . To properly manage the risks connected to, and not reporting onwards to local law enforcement authorities in Haiti, to the Commission or other authorities of, concerns that two girls under the age of 14 might be at risk of sexual exploitation (CCEW, 2019a);20 Four days later, the Commission released its final report, explaining the context to its Official Warning. Exploring Oxfam GB’s handling of the 2011 allegations about its Haiti programme and its safeguarding policies, both historic and current, the report attributed blame to operational staff, managers and trustees alike, noting ‘systemic weaknesses’ in ‘safeguarding matters’ (CCEW, 2019b, p. 15). It criticized ‘weakness in the corporate oversight of safeguarding arrangements at Oxfam GB’ and a ‘gap between its strategy, the strategic intent behind it and its implementation’ (Ibid). Central to such failures, the report argues, was the under-resourcing of the Global Safeguarding Team between 2015 and 2017 when ‘resourcing and capabilities did not adequately match the level of risk faced by the charity, its global reach and the nature of the activities carried out’ (Ibid: 18 & 32). The wider lessons, it argued, were clear: Operating internationally across multiple jurisdictions and cultural contexts and in the midst of humanitarian crisis is a profoundly complex and difficult endeavour and lives depend on the work of UK charities and the thousands of charity workers and volunteers across the world … But failure to take reasonable steps cannot be excused by the difficult context in which a charity works’ (Ibid: 33). In this context, it concluded, ‘an effective culture of keeping people safe identities, deters and tackles behaviours which minimize or ignore harm to people and cover or downplay failures’ (Ibid). The interim and final reports of Oxfam International’s Independent Commission on Sexual Misc