On December 8 2022, the African Development Bank (AfDB)’s Independent Recourse Mechanism (IRM) launched its 2022 Advisory Note on “Preventing, mitigating, and responding to sexual exploitation, abuse, and harassment (SEAH) within AfDB operations.” The Advisory Note examines why it is important for the AfDB to address SEAH at project level, shares lessons learned from World Bank cases in Uganda and the Democratic Republic of Congo, analyzes the gaps in current practice at AfDB, and provides recommendations for how the institution can more effectively address these risks in projects.
BIC welcomes the Advisory Note and its recommendations, including that the AfDB should:
- Institute compulsory SEAH risk rating in projects
- Harmonize the definition of SEAH to include concrete examples of prohibited behaviors
- Provide guidance, tools, and financial and human resources to implement policy requirements
- Amend the Integrated Safeguards System to include SEAH risks
- Include clauses on safeguarding against SEAH within contracts
- Develop a standard operating procedure to address SEAH throughout the project cycle
- Develop clear guidelines on establishing and adapting project Grievance Redress Mechanisms (GRMs) to create safe spaces to report and respond to SEAH cases.
It is critical that the AfDB act to address SEAH, as SEAH is a human rights violation and a well-recognized impediment to economic development, and the failure to respond to SEAH may affect project outcomes as well as the AfDB’s reputation. SEAH risks are present in all countries where the AfDB has operations and have been identified in AfDB-financed projects. For example, in the AfDB-funded East Africa Coastal Corridor project in Kenya, BIC and its local partner organization Collaborative Center for Gender and Development (CCGD) identified cases of SEAH linked to the project and raised them with the AfDB and the Kenyan implementing agency. Unfortunately, AfDB’s response to the reports has been slow and its role unclear vis-a-vis the role of the Kenyan government. This case is a clear example of the urgent need for clear policy, guidance, and leadership on the part of the AfDB acting on the real risks and challenges related to SEAH in the development operations it finances across Africa.
BIC calls on AfDB management to immediately develop and publish an action plan that details its commitment to implementing the IRM’s recommendations and the steps it will take to do so. At a minimum, this action plan should:
- Commit to preventing and responding to SEAH in AfDB operations. It appears that the AfDB previously carried out an internal awareness raising campaign with staff around sexual harassment. However, this campaign did not address SEAH occurring outside the institution in the projects that AfDB finances. AfDB needs to work towards a cultural change such that preventing SEAH is a genuine priority at all levels of the institution. This includes demonstrating openness to recognizing gaps and failures, being vocal about the importance of addressing and responding to SEAH by institutional leadership and operational level staff, and creating a culture of transparency, encouraging instances to be reported and addressed rather than covered up. AfDB should also request an Independent Development Evaluation (IDEV) review every four years to draw useful lessons and promote accountability.
- Include a commitment to develop guidance and continuously build staff and client capacity to address risks of SEAH. To support staff and clients with risk analysis and mitigation measures related to SEAH, including child SEAH, in all AfDB projects, AfDB should develop good practice and guidance notes, borrowing examples from the World Bank and other peer institutions, and should seek stakeholder input during this process. The AfDB should further develop training materials targeting staff and clients to build awareness and capacity to identify, mitigate, and respond to SEAH throughout the project cycle.
- Set up an internal reporting and response matrix in case of SEAH incidence during project implementation. The IRM Advisory Note revealed a lack of clarity around where SEAH cases should be reported and the capacity of various departments within the AfDB to respond appropriately (whether the Office of Integrity and Anti-Corruption (PIAC), Environmental and Social Safeguards and Compliance Department (SNSC), and/or the IRM). It further notes that the responsibility for overseeing SEAH prevention, response, and mitigation within AfDB operations is currently shared among a variety of actors in different units and is not coordinated. Additionally, there are no clear requirements for issues of SEAH within AfDB operations to be reported to the AfDB Board of Directors for the purposes of trend monitoring, oversight and accountability. AfDB staff and management should have a clear reporting matrix detailing when, how, and to whom to report incidences of SEAH, the chain of escalation for reports, and how to respond to reports in a confidential, ethical, survivor-centered, and sensitive way. Having a clear reporting and response mechanism will determine how quickly and effectively SEAH allegations are investigated, responded to, and how soon victims are able to access the support needed.
- Establish clear next steps in terms of setting up responsibilities, timeline and outreach campaigns. The action plan should clearly indicate the actions to be taken in response to the Advisory Note’s recommendations, as well as the timeline, responsible units, and outreach campaigns aimed at driving SEAH awareness amongst staff and clients. Additionally, it should emphasize that all SEAH prevention and response measures must be accessible, people-centered, and designed in a way that enables the safety, dignity, and agency of those affected by AfDB operations. In preparation of this plan, the AfDB should organize extensive consultations with clients, civil society, communities and other key stakeholders to provide input. Once approved, the plan should be made public and widely shared to create awareness, promote ownership, transparency and accountability amongst all stakeholders. AfDB should conduct outreach campaigns aimed at driving awareness among both staff and clients, and should conduct periodic reviews of samples of high risk projects to capture lessons on implementation of the action plan. Additionally, to enable continuous knowledge exchange and learning, the AfDB should organize SEAH learning events at regional and country level involving all stakeholders including children, women, CSOs etc.