International Development Fund: grant awards and management stages

Safeguarding

Media reports arose in February 2018 of serious misconduct and sexual abuse by staff working in the international development sector, specifically in relation to vulnerable groups. In response to this, our grant conditions were further amended from March 2018 to make it explicit that partner organisations must have robust safeguarding policies in place (and have carried out due diligence on their in-country partner in that regard too), and as regards notifying any safeguarding incidents as well as any irregular financial activity.

Safeguarding remains an important consideration for any Scottish Government international development funding. We have therefore continued to review and revise our safeguarding conditions as necessary in the years since 2018. Most recently, having undertaken a further review in 2025 through an independent safeguarding expert, our live safeguarding clauses have again been updated, and included in all new international development funding (note that we also revise existing funding mid-project through a Grant Variation Letter for the next year’s grant).

Our live safeguarding clauses are as follows:

• 4.7A The Grantee must have robust safeguarding policies, procedures and good practice in place to prevent any harm and abuse to all people it has contact with. In particular any harm and abuse that may arise from misuse of power and position of its staff and representatives. Where the Grantee is working directly through a partner organisation, the Grantee is required to have undertaken due diligence in relation to safeguarding arrangements, including obtaining evidence of satisfactory safeguarding policies and/or procedures by the Grantee's partner organisation. The Grantee will ensure that a safeguarding risk assessment has been completed prior to the commencement of the project. The Grantee must report all and any cases of suspected abuse or malpractice relating to anyone involved within the Grantee or its partners, in delivery of the Programme or any beneficiary of the Programme to Scottish ministers and the relevant authorities immediately. The Grantee must, upon request from Scottish ministers, provide copies of the safeguarding policies and procedures underpinned by international standards referred to in this clause and those of their partners
• 4.7B In the event of the Grantee becoming aware of or suspecting:

1. any irregular or fraudulent activity in relation to the Grant or Programme, or any part of either of them and/or
2. any safeguarding incident by or in respect of any person involved in the Programme and/or
3. any credible suspicions of, or actual incidents that are not directly related to this Agreement but would be of significant impact to their partnership with the Scottish Government, including but not limited to events that affect the governance or culture of the Grantee or its partner, or safeguarding incidents involving  communities affected by the Project

The Grantee shall immediately notify the Scottish ministers of such activity or incident and provide such other information as the Scottish ministers may reasonably require in relation to the impact on the Programme and the use of the Grant. In so notifying Scottish ministers, the Grantee must also confirm that such irregular or fraudulent activity or safeguarding incident has been referred to the relevant regulatory or other authorities (if it is safe to do so for the victim/survivor(s)) as appropriate, in line with any statutory duty and otherwise in line with any guidance issued from time to time by either the Office of the Scottish Charity Regulatory (OSCR) or as appropriate the Charity Commission for England and Wales. For the avoidance of doubt, in this agreement, a "safeguarding incident" includes any incident of abuse or mistreatment of any vulnerable person or the misuse of power, authority or position of trust of any person involved in the project, programme, organisation or related entities

• 4.7C The Scottish ministers reserve the right to suspend and/or terminate funding in the event that there is non-compliance with Clauses 4.7A and/or 4.7B and/or if it is of the opinion that the Grantee has failed or neglected in its duty of care to safeguard people and/or prevent financial mismanagement 

Incidents relating to safeguarding in projects/programmes funded through the International Development programme should be reported, in line with the above clauses, to SafeguardingReportODA@gov.scot using the incident reporting form.

Furthermore, every grantee should appoint a designated safeguarding lead to lead on safeguarding policy development and training. The safeguarding lead will be the point of contact for Scottish Government in respect of safeguarding matters affecting their organisation. Every grantee should also provide evidence of compliance with Inter Agency Standing Committee (IASC) six core principles relating to protection from sexual exploitation and abuse (PSEA).

Partner organisations must have robust safeguarding policies in place (and have carried out due diligence on their in-country partner in that regard too), and as regards notifying any safeguarding incidents as well as any irregular financial activity. See an example policy template.

Partner organisations are expected to include a preliminary Safeguarding Risk Assessment during the application process. This will provide reassurance that the applicant has properly assessed safeguarding risks within the project and has identified mitigation actions. This will be submitted alongside the safeguarding policy as part of wider due diligence checks.

It is appreciated that some programmes will have higher safeguarding risks than others therefore the Safeguarding Risk Assessment should be proportionate to the activities being carried out. An example safeguarding risk assessment and an incident reporting form are available in the supporting documentation.