WORKING WITH DG ECHO AS AN NGO PARTNER | 2021 - 2027
SEAH - YEARLY REPORTING ON ALLEGATIONS 2021
Clarifications on the scope of the reporting are available on page 1 of the Guidance.
1st requirement to report:
Allegations against affiliates (i.e. staff members, contractors, volunteers, etc.) of ECHO partners and their implementing partners and contractors (jointly called “Participating Organisations”) provided that they are in any way related to an ECHO grant, regardless whether the victim/survivor is a beneficiary of an ECHO funded grant.
“Affiliates” are members of the staff, people under consultant contract or volunteers.
“Implementing partners or contractors” of affiliates are members of the staff, people under consultant contract or volunteers of the implementing partner or contractor.
“In any way related to an ECHO grant” means that, to a certain extent, an ECHO grant paid in part or in full their salaries, including HQ staff if paid from the 7% administrative costs
2nd requirement to report:
Allegations in which the victim/survivor is a beneficiary of an ECHO grant and which occur in the framework of the implementation of an ECHO grant, regardless of who the perpetrator is.
“In the framework of the implementation of an ECHO grant” means that ECHO partners are responsible for the smooth and safe implementation of their activities. If an incident happens in a place (ex.: hospital, refugee camp) or during an activity (ex.: distribution of food) that the partner is managing, the ECHO partner is supposed to report. If the incident happens when the beneficiary is, for example, at home, ECHO partner is not responsible and there is no need to report.
ECHO asks to report sensitive cases as soon as possible, even if not related to an ECHO grant, because they risk resulting in media attention and might lead to questions from the budgetary
authority (Council and European Parliament). This is important in order to provide timely and consistent replies.
Sensitive cases go beyond the fact that they are related to an ECHO grant and include, as an example:
High political profile of the perpetrator: if, for example, the chief officer of the organisation is involved, this could put at stake the partnership with ECHO, unless the partner adopts all necessary measures very fast.
The negligence in the management of allegations that allowed the perpetrator to act with impunity for a certain period of time: even if it is not related to a DGECHO grant, it shows weaknesses related to the detection part of safeguarding policy of the organisation as a whole.
A sensitive case creates a high reputational risk for the partner and, by extension, for the donors.
Ref.: Guidance note, section IV. “Reporting of critically sensitive allegations of SEAH” (page 6).
The reporting has a clear focus on SEAH. In question A.7, please include other types of misconduct as specified in Art. 4.9 of the certificate.
In section B, please only include the follow-up of SEAH allegations.
Child abuse should be recorded under A.7 as “other unethical behaviour” (ex.: child labour, forced child labour, see also Art. 4.9 and 5.3 of the Certificate).
If it is a case of sexual exploitation, abuse or harassment of a child, the partner has to report it as such in the corresponding row.
“Other policy breaches” refer to unethical behaviours listed in article 5.3 of the Certificate:
“discrimination, forced and child labour, modern slavery,  exploitative practices towards staff, partners, contractors or beneficiaries, illegal  employment and intentional environmental damage in accordance with the applicable Commission guidance”.
For implementing partners, does the organisation have to report for all of them?
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.
When the implementing partner is also an ECHO partner, it has to report on the SEAH cases that have happened in the implementation of the grant, 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.
If an ECHO partner did not receive any ECHO grant in year n-1, the partner only needs to fill in section C of the report.
Please also include a short message stating that you did not fill in the other sections because you did not sign any grant with ECHO in 2021.
If the incidents falls under the scope of “sensitive case” (ex.: the perpetrator is a member of the board of the organisation or the issue is so serious that it puts in question the whole policy of the organisation because of a systemic problem in the treatment of the allegations), the ECHO partner has to inform ECHO as soon as possible.
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.
The questions in section C refer to all staff, regardless of their relation to ECHO grants.
Please also see the updated instructions in the guidance document and in the reporting form.
Please apply the same definition for your organisation as you did in the ex-ante assessment.
Signing the MDS is a good practice, but not a mandatory requirement for partners. It avoids that a perpetrator is re-hired, and in a position to perpetrate an act of sexual exploitation or abuse.
Each case / incident should be counted as one allegation.
Regulation (EC) No 1049/2001 on public access to European Parliament, Council and Commission documents (OJ L 145, 31.5.2001, p. 43–48) intends to provide access to public documents as well as to strike a balance between transparency and a risk of harm to certain public or private interests resulting from a disclosure of certain documents. DG ECHO, as Commission department, is bound by this Regulation. Corporate Commission procedure, which applies to DG ECHO, requires the systematic consent of the organisation involved prior to the disclosure of documents. In case ECHO receives a request for documents for the reported data, ECHO will only disclose the information after approval by the partners.
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).  After the first round of reporting, ECHO will carry out an analysis of this report and enter into a dialogue with the partners.
DG ECHO commitment with the donors’ community is to collect the figures for discussion. At this stage, the Commission is not planning to share the aggregate report.
In case of doubt, please include the case in the reporting.
When providing quantitative data, partners demonstrate to have in place an effective safeguarding policy, especially for detection of incidents and response, which is a requirement for ECHO partners.
At the same time, DG ECHO will be as flexible as possible during the first year of this exercise.
DG ECHO remains open to discuss with partners if some information is not feasible to retrieve at the end of this first exercise.