PSEAH in IFIs: Progress, Gaps and the Road Ahead

The following practical, targeted recommendations are designed to strengthen future IFI efforts on PSEAH on the basis of the findings of this report. As the global financial situation increases SEAH vulnerability amongst communities served, decision-makers in IFI leadership, management, and executive boards must jointly engage to renew commitments and financial efforts.  

Recommendation 1: Renew IFIs’ joint commitment on PSEAH, aligning with CAPSEAH, the most recent international PSEAH framework

Rationale: Since the 2018 joint commitment to PSEAH, global benchmarks and expectations have advanced, most recently with CAPSEAH. Several IFIs align informally with CAPSEAH principles and minimum actions and use them in their work, but they have not updated their collective pledge. The original commitment spurred substantial guidance, tools and GPNs, but most of these remain varied, voluntary, and practice varies widely. Consequently, partner countries and individual clients face multiple requirements. The differences in institutional PSEAH-related standards create hurdles for IFIs to co-operating in operations, which limits their ability to strengthen PSEAH (and GBV more broadly) through national systems or private sector partnerships. Shareholders and practitioners call increasingly for harmonised minimum standards to boost coherence and collective impact. They also call for a shift towards coherent, operationally grounded, survivor-centred collective accountability.

Actions for Management:

• With other IFIs, renew the joint commitment on PSEAH to align with CAPSEAH.
• Harmonise standards for PSEAH in E&S frameworks, aligning with CAPSEAH.
• Develop a common reporting framework for joint IFI progress reporting based on CAPSEAH principles and minimum actions for annual reporting (see Recommendation 5).

Actions for Member states:

• Call for a renewal of the joint IFI Commitment on PSEAH, aligning at least with CAPSEAH minimum standards.
• Call for a joint annual progress report of IFIs, benchmarking themselves against CAPSEAH.
• Encourage stronger IFI collaboration through harmonised standards and joint capacity-building.
   

Recommendation 2: Deepen collaboration on PSEAH across the IFIs, the UN, and other partners

Rationale: Collaboration across IFIs has expanded, yet harmonisation remains partial and operational co-operation uneven. Joint diagnostics, training, and mutual reliance frameworks could reduce duplication, ease burdens on governments, and improve efficiency, provided safeguards are in place to avoid lowering standards. Collaboration between IFIs and the UN has also begun but is not yet benefitting from their complementary strengths. Many IFIs hold financial leverage and authority with governments and with the private sector, while the UN brings technical PSEAH expertise and links with civil society. Together they could exert more coherent pressure for systemic reforms and foster a stronger enabling environment for GBV/SEAH prevention and response at the country level. Also, UN agencies and NGOs often provide survivor services on which IFI clients can depend but shrinking humanitarian and gender funding make this reliance precarious. Unless IFIs and UN re-think and institutionalise their partnerships, critical gaps in victim support will persist and likely worsen. Expanding collaboration — among IFIs themselves, with the UN, and with civil society — through joint initiatives, shared analysis, indicators, and participation in misconduct databases would maximise scarce resources, ensure sustainable survivor services, and reinforce systemic change.

Actions for Management:

• Expand operational collaboration with IFIs and the UN through shared diagnostics, service mapping, tools and capacity development.
• Continue working with other IFIs towards policy convergence to foster collaboration, including through mutual reliance frameworks, thereby reducing duplication and administrative cost for governments, companies and clients, and maximising impact (see also Recommendation 1).
• Harmonise E&S standards, due diligence, project and community reporting standards, and contractual requirements among IFIs regarding PSEAH, as well as PSEAH M&E indicators.
• Consider new models of partnership with UN agencies and civil society for survivor assistance, given that current reliance on these actors is becoming unsustainable with shrinking humanitarian and gender funding.
• Participate actively in global misconduct mechanisms (ClearCheck, Misconduct Disclosure Scheme, Project Soteria), with the necessary safeguards against the misuse of data, to prevent hiring staff with a track record of misconduct.

Actions for Member states:

• Incentivise IFI collaboration, including shared indicators, harmonised standards and due diligence, joint reporting on PSEAH (see Recommendation 1).
• Establish a pool of resources for joint-IFI global public goods for PSEAH (such as SEAH investigator qualification systems, harmonised tools, survivor-support networks).
• Bridge the gap between IFIs and the UN on PSEAH, encouraging collaboration that harnesses IFIs’ financial leverage and the UN’s normative, technical and diplomatic roles.
• Facilitate/encourage partnerships between IFIs and the UN at country level.
• Find solutions on funding survivor services (to which IFI grievance mechanisms refer survivors) predictably where governments and other actors lack capacity.
• Incentivise alignment of IFI–UN efforts through shared reporting or pooled funding arrangements.
  

Recommendation 3: Build an institution-wide vision for protecting from SEAH.

Rationale: Most IFIs still lack a board-approved, institution-wide vision for addressing SEAH, which weakens leadership and follow-through on their joint commitments. A strategic vision is a prerequisite for stronger leadership and facilitates aligning capacity and approaches with stated commitments. Without an overarching framework linking GBV and SEAH, IFIs risk treating PSEAH as a compliance exercise rather than a development challenge that should shape operations, country engagement and internal culture. The lack of a strategy helps explain why PSEAH rarely features in high-level country strategies, despite entry points (for example, the World Bank’s “Overview Assessments”) and project risk management can unlock wider GBV work and financing. A coherent strategy would also reduce fragmentation in internal systems by clarifying roles, strengthening coordination across functions, and improving end-to-end survivor support and reporting. Executive boards should therefore require each IFI to adopt an institution-wide PSEAH policy, backed by regular, transparent reporting on implementation.

Actions for Management:

• Develop a holistic, whole-of-institution PSEAH vision and strategy that links internal misconduct systems with operational safeguards, public and private operations and country-level engagement into a single, coherent framework (including internal misconduct, country engagement and operational risk management) and aligns with CAPSEAH principles and minimum actions.
• Integrate PSEAH into E&S frameworks with an explicit prohibition and mandatory risk procedures.
• To position the vision in current circumstances, instruct country offices to assess and understand how the institution’s PSEAH commitments are affected by global financing cuts to the HDP system touching the peer organisations they rely on for prevention and assistance, and draw consequences.

Actions for Member states:

• Call for and endorse board approved, organisation-wide strategies for SEAH/GBVH that integrate internal misconduct systems and country engagement into a single, coherent framework, and align with CAPSEAH minimum actions.
• Call for a consolidated annual report on PSEAH related to this strategy (see Recommendation 5).
  

Recommendation 4: Strengthen leadership for PSEAH

Rationale: IFIs have committed to fostering a culture of respect and high standards of ethical behaviour across institutions. Many have committed to “zero tolerance” for inaction on SEAH. Doing so requires strong leadership. Yet leadership for PSEAH varies significantly across IFIs and remains too limited to position it strategically as a core development issue. With weak leadership signals, PSEAH struggles to gain strategic traction, is less likely to receive dedicated staffing, sustained funding, or the institutional visibility needed to support its effective implementation. Clear prioritisation through institutional strategies is essential to set expectations for staff, clients and partners. This means that senior leadership must be explicit when it comes to prioritising PSEAH in resource allocation, defining clear responsibilities, communicating visible examples of good internal and external practice and monitoring and evaluation.

Actions for Management:

• Assume clear leadership regarding PSEAH for the institution, supporting a whole-of-institution strategy (Recommendation 3), appointing champions and defining clear responsibilities.
• Strengthen the dialogue on SEAH with member states, industry bodies, financial intermediaries, borrowers and clients (as part of the wider GBV dialogue).
• Create structure and visibility for PSEAH efforts (communication, action plans, etc.).
• Share lessons from any existing internal culture initiatives and long-term prevention efforts.

Actions for Member states:

• Position PSEAH as a strategic issue for IFIs, integrating it as a standing agenda item on board meetings to reinforce visibility and accountability.
• Pursue multi-stakeholder policy dialogues with IFIs, the UN, and civil society to speak with one voice on PSEAH.
• Endorse CAPSEAH to show commitment to aligning with a wider range of stakeholders.
  

Recommendation 5: Increase transparency and accountability in reporting

Rationale: In recent years, there have been strong calls for more transparent public reporting on PSEAH from IFIs to demonstrate accountability and allow stakeholders to understand if and how IFIs are meeting their commitments, appraise progress, exercise appropriate oversight and support further action. This entails two types of reports: progress reports (on implementing PSEAH measures) and incident reporting. Transparent reporting enables institutions to identify patterns, learn from recurrent risks, and strengthen safeguards, operational response, and survivor assistance. Yet, reporting on PSEAH in IFIs is weak.

• The joint IFI reporting on progress made between 2018-24 has formally ended. It is unclear how IFIs will publicly report on their joint progress in the future.
• At the institutional level, aggregate reporting lacks any SEAH data collected in operations. Both process updates on PSEAH risk management (how IFIs and their clients assessed, prevented and managed risk) and information on incidents (numbers) and how clients and IFIs responded to them, are currently fragmented or lacking altogether. Sustainability reports emphasise climate and environment but rarely cover SEAH.
• Reporting on internal sexual harassment and misconduct is dispersed across different reports and usually includes only SH; it does not usually include SEA perpetrated by staff, which makes it difficult to understand the full picture and assess whether responses are adequate. This can undermine trust in internal justice systems.

Public reporting is limited to staff misconduct and to a few IFIs such as the WBG and IFAD, but even for this, there is no consolidated board-level report. By contrast, at the UN, such reporting is mandatory and a regular item on board agendas. Bottlenecks to transparent reporting in IFIs include poor risk identification, insufficient monitoring capacity, lack of harmonised M&E frameworks, technical challenges, and confidentiality concerns.

Actions for Management:

• Develop a common reporting framework for joint IFI progress reporting, based on CAPSEAH principles and minimum actions for annual reporting (see Recommendation 1).
• To improve reporting on progress in implementing PSEAH institution-wide:

    o Produce a regular institutional report that provides process updates on how the organisation has implemented its institutional commitment on PSEAH.

    o Move to more integrated digital platforms to support E&S framework implementation, by embedding SEAH risk assessments, actions, monitoring and management directly into institutional portals that integrate prevention and response and produce aggregated information.

    o Link progress reporting on PSEAH with (public) accountability mechanisms (project closure, audit and evaluations) to promote transparency.

    o Treat mitigation plans as living documents that are clearly updated, disclosed and reported against. Introduce a formal update at mid-term, agreed with clients, and a formal closure report (like what is done for development results).

• To improve incident reporting of internal and external SEAH incidents:

    o Publish aggregated and anonymised SEAH incident data from operations (as in sustainability reports); and internal misconduct.

    o Report not only allegations but also response/incident handling and survivor assistance provided.

    o Align with good practice on transparent, anonymised reporting, such as guidelines set used by the UN in the Harmonised Reporting Scheme, collecting and reporting comparable data on SEAH to analyse trends and patterns and learn.

• Build on ENMO’s role as a forum for exchanging information, experience, and ethics standards, and make collaboration in the ENMO network more systematic and transparent, including through more regularised engagement and clearer shared communication practices.

Actions for Member states:

• Request consolidated annual reports on SEAH risks, incidents, and follow-up (including assistance), encouraging IFIs to make PSEAH part of their public risk reporting, like climate disclosures.
• Ensure that reporting on the implementation of internal and operation-related PSEAH measures becomes a standing item on board agendas (see Recommendation 4).
   

Recommendation 6: Complement the compliance approach with measuring effectiveness and learning

Rationale: Current reporting on PSEAH efforts in operations is heavily compliance oriented. It focuses on activities such as CoCs introduced, training delivered, or the existence of grievance mechanisms. Ensuring compliance is indeed crucial in the IFI business model. Yet IFIs rarely assess the results of E&S measures,⁶² including in preventing SEAH or protecting survivors. Portfolio reviews and staff surveys, for example, remain underutilised and the uptake of guidance notes is uneven. Effectiveness data could inform strategic resource allocation and enable institutional learning. Greater attention to knowledge management, learning, and sharing of lessons, supported by digitalisation, is essential to strengthen accountability and close the gap between policy standards and practice.

Actions for Management:

• Complement compliance checks with effectiveness evaluations, for example, on whether GMs are trusted, survivors protected, and prevention in place and effective.
• Allocate funds for independent evaluations that assess the effectiveness of PSEAH efforts.
• Strengthen PSEAH monitoring frameworks, including by establishing shared indicators for standardised client reporting.
• Invest in digital systems and dashboards that allow portfolio-wide analysis (Recommendation 5).
• Ensure positive performance management for managers and country directors enforcing PSEAH measures.

Actions for Member states:

• Ask that IFIs undertake independent evaluations and shared learning initiatives that assess the effectiveness of PSEAH efforts.
• Ask for regular reporting on the implementation of E&S policies by IFIs and their clients that includes effectiveness and impact, including on SEAH.
• Treat rises in the number of cases as a positive indicator of trust in the system and proactively enquire about the absence of reported cases as a potential red flag.
  

Recommendation 7: Ensure that institutional capacity for PSEAH reflects the scale of risk. Ensure predictable funding and institutional capacity for portfolio-wide GBV/PSEAH action

Rationale: At a moment of heightened pressure on development finance, robust PSEAH systems are fundamental for IFIs to uphold the highest standards of accountability and remain trusted partners. In this context, building the right systems and expertise to prevent SEAH is a sound investment that far outweighs the costs and harms SEAH can cause. Currently, resourcing for PSEAH in IFIs is fragmented, often short-term, unpredictable, and HQ-centric. Specialist capacity dedicated to GBV and SEAH is insufficient to cover large portfolios and not always allocated in line with the risk present in specific operations. This limits the quality of E&S supervision for SEAH and presents a risk.

In operations, IFIs need to ensure clients and partners have capacity to prioritise prevention and victim services. However, where national systems are weak, this commitment risks being hollow unless governments allocate sufficient resources in project budgets for GBV/PSEAH measures, systematically linked to SEAH risk levels (in such contexts, counterpart financing from the borrower is unlikely), and allocate sufficient resources to predictably finance accompanying measures, local GBV services and GBV reforms. Where governments are reluctant to borrow for this, concessional funding and trust funds remain critical.

Institutional capacity is not only about staffing and financial resources. It is also about having the right technical and digital systems in place. This requires investment in integrated systems that enable IFIs to monitor portfolio-level risks, demonstrate compliance, and identify and take up lessons.

Adequate resourcing depends heavily on how much boards prioritise this issue and IFI managements exert leadership. Closing this gap will require IFI senior leadership to champion PSEAH, and develop institutional capacity in a systematic way, and simultaneously advocate for strengthening country capacity.

Actions for Management:

• In their own ranks:

    o Invest in SEAH/GBV specialists at HQ and country level, expand training and SOPs for clients, contractors, and governments, and promote collaboration with UN partners to reduce duplication and government burden.

    o Ensure that institutional capacity includes strong technical and digital systems that match the scale of operations and risks.

    o Implement existing initiatives such as Misconduct Disclosure Scheme (MDS) and INTERPOL/Soteria to mitigate the risk of re-hiring individuals with records of sexual crime or misconduct.

• In operations:

    o Require that project-level prevention and response plans include dedicated budget lines for GMs, gap filling financing of quality response services, training, monitoring, and for screening and vetting mechanisms (such as MDS and INTERPOL/Soteria).

    o In private sector investments with financial intermediaries, require that PSEAH expectations, including on resourcing, extend through Private Equity Funds’ E&S management systems to on-lending portfolios, with clear and minimum requirements for stakeholder engagement and grievance mechanisms down the chain.

    o Add conditions for contractors/subcontractors: Ensure that funding agreements or company contracts include explicit conditions for SEAH prevention and response, such as mandatory policies, reporting mechanisms, and dedicated resources for training and victim support.

    o Engage with other IFIs to jointly train borrower partners at scale and support country-tailored models where local institutions are trained and supported to expand institutional capacity and strengthen national systems.

• With respect to governments and peer organisations:

    o Promote portfolio-wide approaches by negotiating with host authorities so that a share of projects support enabling-environment work.

    o Use trust funds strategically for PSEAH to complement other finance, consider co-financed technical assistance windows to pool resources across IFIs, or invest in related global public goods such as community-based complaints mechanisms, investigations qualification training schemes, misconduct disclosure scheme, or harmonised reporting schemes that will benefit them and clients.

    o Coordinate more closely with peer organisations in supporting sustainable national systems.

Actions for Member states:

• Strengthen the understanding of the cost of effective prevention compared to investment in response.
• Support IFIs’ budget requests for specialist GBV capacity and support management in expanding GBV specialist staffing, resourcing capacity-building initiatives.
• Emphasise the need for a minimum standard for institutional PSEAH capacity, beyond which (institutional) capacity is continuously adjusted to the risk in specific operations benchmarked against the portfolio.
• Encourage management to allocate adequate operational budgets for monitoring missions and field-based supervision by PSEAH focal points, rather than relying on desk-based oversight.
• Link budget allocations and the SEAH risk profile of portfolios clearly.
• Develop country strategies to integrate GBV/PSEAH beyond project safeguards, identifying entry points and positioning it as a portfolio-wide priority.
• Resource stable concessional financing or contribute to pooled funds, trust funds and grant facilities that incentivise governments to strengthen enabling environments to prevent and respond to GBV/SEAH.
• Strengthen and support national civil society as an important part of the “enabling environment” and entry point for funding GBV services, ensuring at least a basic first response capacity even in remote or under-resourced settings.
  

Recommendation 8: Adopt shared minimum requirements for grievance mechanisms

Rationale: Although most IFIs have multiple grievance channels, no common standards exist across them
for handling SEAH-related cases. Project-level mechanisms often lack confidentiality and expertise, reducing trust and use. Referral pathways are inconsistently mapped, or mapped in ways that create harm, and quality is not systematically assured. GPNs refer to survivor-centred approaches, but these approaches are rarely embedded as mandatory requirements and reporting practices too often continue to undermine the autonomy of survivors. Minimum standards, quality assurance, and coherent referral systems would ensure that survivors can decide how to deal with their individual situations, report safely should they choose to, access services should they choose to and have the option of receiving redress, shifting grievance systems from formality to effectiveness.

Actions for Management:

• Introduce mandatory quality assurance of GMs.
• Introduce a requirement that staff managing GM (both for the institution and in operations) have SEAH-specific expertise.
• Embed survivor-centred approaches in legal agreements, safeguard frameworks and investigations.

Actions for Member states:

• Ask IFIs to introduce harmonised minimum standards for GMs, with requirements for referral pathways.
• Support capacity-building initiatives that strengthen victim-survivor referral services.
• Support local response capacity through community-based mechanisms and local civil society (see Recommendation 7).
   

Recommendation 9: Define and embed survivor-centred approaches

Victim-/survivor-centred approaches remain a weak area of PSEAH performance across IFIs, reflecting a gap between policy commitments and operational practice. When referral pathways are unclear, services unavailable, specialist capacity thin, and follow-up responsibilities diffuse, approaches are not centred on victim-survivors’ needs. They undermine accountability, compound harm, erode trust in reporting systems and limit institutional learning. IFIs need to move from principles to operational requirements by embedding VCAs consistently in safeguards, legal agreements, and oversight practices—especially in higher-risk operations—while investing in the capacity of borrowers/clients to deliver safe, confidential, consent-based responses. This requires mapping and resourcing referral pathways; setting minimum standards for service quality (and addressing gaps); ensuring trained specialists interface with victim-survivors; and promoting victim-survivor-centred investigation practices that protect safety, agency, and confidentiality; and supporting follow-up and remedy.

Actions for Management:

• Operationalise VCAs in safeguards and supervision, specifying roles, escalation thresholds, and time-bound follow-up responsibilities across the institution and in operations.
• Ensure referral pathways at project level: Map and quality-assure services, so consent-based referrals are feasible in practice.
• Put trained expertise with SEAH/GBV capacity at the point of contact for internal misconduct, and ensure clients/borrowers do so as well, so that interactions with survivors, including investigations, are victim-survivor centred.

Actions for Member states:

• Set enforceable VCA expectations: Require VCAs to be anchored in safeguards/E&S standards, legal agreements, and supervision requirements, with operational detail reflected in guidance.
• Fund VCA delivery capacity: Resource country-level specialist support and local survivor services/referral networks, especially in low-capacity contexts.
• Require evidence of survivor-centred follow-up: Ask for reporting on referral pathway functionality, informed consent/confidentiality practice, and documented follow-up/remedy in higher-risk operations.
  

Recommendation 10: Leverage private‑sector operations strategically to reinforce uptake of PSEAH standards

Rationale: Private sector firms are central to promoting GBV/PSEAH standards across communities. IFIs can do more to fully leverage the private sector’s potential to strengthen SEAH prevention and accountability. While in sovereign operations, an IFI’s PSEAH safeguards only affect contractors in a specific project, IFIs’ private sector arms can introduce requirements for companies and financial intermediaries that can shape norms and influence market behaviour at scale. To explore potential synergies, these public and private sector arms need to be more coherent. To date, guidance often targets sovereign borrowers and does not translate well to private-sector realities or instruments, and legal covenants are difficult to apply consistently across multiple financing products, including with financial intermediaries such as banks, small and medium-sized enterprises, funds and insurers.

Challenges specific to private sector operations also merit addressing. Co-investments add complexity and can leave IFIs exposed to SEAH risk even with small stakes. Layered financing structures (financial intermediaries) increase distance from operations, prevent or dilute oversight, and reduce visibility over safeguard implementation, making PSEAH harder to monitor and enforce. Weak environmental and social management systems and inconsistent GMs further limit effective prevention, accountability and survivor-centred responses.

Actions for Management:

• Integrate private sector considerations into an overarching institutional PSEAH strategy (see also Recommendation 3).
• Mobilise the role of companies as advocates, service partners, innovators and community anchors towards local administrations to deepen IFIs’ impact on GBV and SEAH.
• Establish joint protocols in joint investments for sharing risk assessment and information-sharing on SEAH and for cost-sharing among investors for SEAH prevention and response.

Actions for Member states:

• Emphasise the role of national private sector partners in PSEAH and promote their integration into the bank’s larger vision for PSEAH.
• Insist on solid PSEAH requirements In co-investments, offering specialised expertise (technical assistance) to make this effective.