The Charity Commission has issued a formal regulatory alert to charities operating in Ukraine and the surrounding regions to raise awareness of the risk of sexual exploitation, abuse and harassment.
The alert reiterates the duty that all trustees have to take reasonable steps to protect from harm people who come into contact with their charity. In particular, the alert outlines specific steps that the Charity Commission expects charities operating in Ukraine to take to keep people safe. These steps include the following measures:
- Assess and manage safeguarding risks, including the risks of sexual exploitation, abuse and harassment,
- Regularly review existing safeguarding policies and procedures to ensure that they remain appropriate and fit for purpose as the situation in Ukraine evolves,
- Ensure that trustees, staff and volunteers are suitable and legally able to act in their roles (for example, by carrying out and updating the relevant vetting checks),
- Implement training plans, especially following new recruitment,
- Use (or join) the Misconduct Disclosure Scheme (a system that aims to increase the sharing of sensitive information between organisations) to reduce the risk that individuals who pose a risk can move between agencies), and
- Ensure that everyone connected to the charity understands how (and feels able) to report concerns.
The alert is clear that the Charity Commission expects charities to make sure any partner or organisation they fund has appropriate safeguarding procedures in place – and will hold charities to account for their supervision of safeguarding risks in relation to any overseas partners.
There is also a reminder in the alert that charities must respond quickly and appropriately where allegations/incidents arise. This will include providing support to victims and survivors and reporting to the relevant agencies and regulators as appropriate (for example, local police and the Charity Commission).
Clearly, it is important that all charities providing humanitarian aid (or otherwise operating in Ukraine) ensure that they take the steps outlined in the alert. More broadly, the alert highlights the importance for trustees to consider the appropriateness of their safeguarding approaches in light of changing current affairs, and not only at annual reviews. Certain events or trends may mean that the risks a particular charity faces are increased or changed so that procedures that were previously sufficient to address those risks are no longer appropriate.
Safeguarding should be central to every charity’s culture and be the subject of regular discussion. This will also help to ensure that safeguarding is at the front of leaders’ minds when things change so that they can be quick on their feet to adapt their charity’s safeguarding approach and keep people safe.