Action Against Hunger is a global leader in the prevention and treatment of life-threatening hunger. It is a humanitarian and development NGO and is at the forefront of responding to major crises, as a member of the Disaster Emergencies Committee (DEC). We supported more than 28 million people across 55 countries in 2022.  

We advocate and campaign globally on the drivers of and responses to hunger, such as climate change, conflict and gender inequality. We are long term implementing partner to the FCDO in their global fight to end hunger and malnutrition and have been at the centre of advocacy and campaign efforts to tackle child wasting, respond to the East Africa food crisis, and to break the cycle between conflict and hunger. 

1. The effectiveness of the FCDO and UK Government’s approach to achieving Sustainable Development Goal 2 (SDG 2) in countries eligible for Official Development Assistance (ODA), including:

1.1. Relevant strategies, aid spending and programming, and other work.

1.1.1.       Despite the international community’s Sustainable Development Goal (SDG) to end hunger by 2030, the number of people facing extreme food insecurity around the world has risen. Since 2015, over three million children have died each year from malnutrition related causes, and it is projected that almost 600 million people will be chronically undernourished by 2030[1]. To deliver impact on malnutrition, it is essential that a broad package of nutrition specific and nutrition-sensitive programmes have the resources required to compliment programmatic and diplomatic action on food security. The UK Government has played an active role in tackling malnutrition since founding the Nutrition for Growth (N4G) initiative, alongside Japan and Brazil, and hosting the first ever N4G summit in 2013.

1.1.2.       In this context, the recent steep decline in the UK’s ODA budget from 0.7 per cent to 0.5 per cent of the UK’s gross national income (GNI), disproportionately impacted UK ODA to nutrition, with 2021 disbursements to nutrition specific investments below 2013 levels. This comes at a time when the UK Government can least afford to turn its back on tackling the causes and consequences of hunger and humanitarian crises. Had the ODA cuts been applied evenly, the 2021 FCDO nutrition financing would have been approximately $732.2 million based on the 2020 disbursement ($1,018.6 million). The actual disbursement of $389.4 million represents a shortfall of around $333.8 million[2]. Notably, the FCDO reduced the funding for two grants (in Somalia and Nigeria) that Action Against Hunger had signed in prior years and, in 2022, stopped funding a third grant that we were in the process of implementing in Nigeria. The cuts to these grants totalled over £5.7 million. This reduced funding meant that we were not able to treat as many malnourished children as we had expected to in the relevant programmes.

1.1.3.       UK ODA for nutrition[3] has been disproportionately cut and forecasts suggest further reduced spending. As the ODA budget recovers, nutrition must be a thematic priority for the UK, if the government is serious about getting back on track to achieve SDG2. Improving nutrition and reducing the number of young children dying every year from malnutrition involves acting before a crisis occurs, such as investing in health systems strengthening, increasing access to a comprehensive range of basic nutrition services and addressing the underlying causes of hunger and malnutrition.

1.2. Approach and work over the short-, medium- and long-term.

1.2.1         The UK’s ability to quickly respond to emerging humanitarian situations to prevent long-term issues has been drastically reduced by the merger of DFID and the FCO. In many least developed and conflict affected countries, DFID played a central role in Humanitarian Country Teams, provided thought leadership and was a strong interlocutor with national governments on humanitarian matters. The UK was often the first responder, and coordinated and galvanised action from other donors; as with the 2017 East Africa drought response. Since the merger, the UK’s approach to humanitarian action has led to sharply declining visibility, with the UK retaining minimal presence in the humanitarian cluster system

1.2.2         This has contributed to a poorer and a more fragmented donor response to crises, with more divergent responses from donors including the UK, EU, SIDA and the US. The UK is missed from both a funding and influencing perspective and should rebuild this capacity and go beyond it, to promote a higher risk tolerance and flexibility for countries with high humanitarian needs, including in fragile and conflict affected states.

1.2.3         The UK made steep cuts to the ODA budget in 2020. Now other donors are cutting their ODA budgets too. A consequence of this is that with less ODA funding available in food crisis hit regions like East Africa to invest in prevention activities such as pre-positioning aid, cash programming, preventative malnutrition programmes and improving household water security. In the new International Development White Paper, a commitment to anticipatory action and humanitarian crisis prevention is clear[4].

1.2.4         However, in reality, our country teams report that when resources are scarce for actors working across humanitarian programming and prevention/ anticipatory action, it is the latter activities that must be cut. In Ethiopia, currently, most programming for the prevention of child wasting is now cut, and only critical wasting treatment programmes remain, due to steep budget reductions from the donor community.

1.2.5         To reflect that crises are now more complex and protracted nature of crises and to support the UK’s commitment to localisation, more multiyear and flexible funding is needed to enable partners to work rapidly and responsively to emerging challenges in volatile contexts. The new White Paper recognises the role of conflict in driving food insecurity[5]  and is ambitious on conflict prevention, but we would have welcomed more on food crises prevention in conflict affected regions.

1.3. Whether the FCDO sufficiently targets and reaches the most in-need communities.
 

1.3.1.       Action Against Hunger’s teams have noted that the FCDO’s current approach does not consistently enable partner agencies to tackle the drivers of malnutrition adequately and effectively. FCDO maintains an output-oriented approach defined by shorter term contracts which limits partners capacity to support the long-term resilience of communities. The average duration of contracts signed between Action Against Hunger and FCDO since 2021 is just 1.5 years and only 33% of contracts last for more than 2 years.
 

1.3.2.  Effective programming to end hunger requires long-term support to communities to promote lasting change. Considering the nature of hunger as a holistic problem, programmes should be inter-sectoral, long term and flexible to adapt to the changing needs of communities. Such an approach would also strengthen programmes to prevent rather than respond to malnutrition which would be better value for money as well as crucially ending preventable deaths. Moreover, FCDO’s pivot to commercial contracts premised on a payment by results approach does not reflect the needs and reality of humanitarian programming and often fails to meet the needs of communities.

1.3.3.  Regardless of the implementing entity, communities need to be involved at an early stage in project and programme design.  Too often, donors seek to invest in activities that are replicable, when in fact good development often means programmes that are uniquely matched to local needs and culture. A good example of putting this principle into practice is Nutrition Causal Analysis (NCA), which is a participative, mixed method research approach used to identify the causes of under-nutrition in each context and to promote the implementation of programmatic responses adapted to these causes.
 

1.3.4.  We welcome the non-project attributable costs (NPAC) approach as it promotes a transparency in providing indirect costs, which strengthens institutional capacity which allows organisations to respond rapidly and at scale in emergencies and prevent nutrition crises from escalating. Furthermore, we are pleased that in some contexts FCDO is promoting the NPAC approach for local partners as well as INGOs, as in the case of the HARBS Emergency Response Programme,  a unique collaborative effort delivered by the Building Resilient Communities in Somalia (BRCiS) Consortium.

1.3.5.  Nonetheless, the FCDO should provide more resources and support to INGOs and local partners to develop the financial capacity of local partners to integrate NPAC. Local partners are first line responders and have the capacity to respond in hard-to-reach communities where INGOs cannot access.

1.3.6.  When provided, Early Market Engagement Events (EMEs) hosted by FCDO are a keyway for suppliers to provide feedback on potential plans by FCDO including in how they can best reach their aim to achieve SDG 2. However, EMEs are not always provided, nor timely, and FCDO does not have a harmonised global approach to procurement, contracts, and project design. Action Against Hunger has been involved in 8 proposal development processes in the last 12 months, none of which used the same templates or guidance for suppliers. NPAC methodology is not consistently applied.

1.3.7.  Inefficient use of INGO resources occurs when they focus on understanding individual procurement processes rather than the humanitarian context. FCDO's consistently tight timelines and failure to adhere to deadlines impede accurate needs assessment and community involvement in program design. This reflects a lack of FCDO capacity and will to timely and effectively channel funds to communities in need.

1.3.8.  Additionally, there are numerous examples where FCDO’s shifting priorities have impacted vulnerable communities. As an example, the FCDO had long standing health and nutrition programmes in western and central regions of DRC (Democratic Republic of the Congo) (Kasai Oriental, Mai Ndombe). Thanks to FCDO funding, Action Against Hunger treated over 12,000 children under 5 for severe acute malnutrition between March 2022 and February 2023 in year 2 of its 2-year PUNCH programme which followed from various iterations of FCDO nutrition programming. FCDO was the only donor working on nutrition programming in these regions. However, in 2023, FCDO shifted funding to prioritise responding in the eastern regions of DRC even though there are already a plethora of other donors working in these communities. Malnutrition continues to be a driver of child mortality in western and central DRC, yet communities have been left without adequate facilities to treat malnutrition since the PUNCH programme ended in February 2023. Programmes must be defined and driven by the needs of vulnerable communities.
 

2. The way the FCDO assesses its work in tackling hunger and malnutrition and if these measures and markers are adequate.

2.1. We welcome the launch of the UK’s new White Paper which is wide-ranging and comprehensive and addresses the drivers of world hunger such as climate change, conflict and gender inequality. However, geopolitical interests still play an oversized role in determining ODA allocation which, coupled with multiple changes of political leadership, has meant a constantly changing set of ODA priorities that do not fit with a needs-based approach.

2.2. The merger of DFID and the FCDO has worsened ODA transparency, oversight, and accountability. DFID ranked highly in the International Aid Transparency Index (IATI), but the FCDO has recently dropped seven places to 16th in the IATI ranking, meaning there was no UK agency in the ‘Very Good’ category for the first time since the Index began[6]. The lack of data (performance, beneficiaries, finances) limits accountability and the department’s capacity to make the changes needed to improve the quality and effectiveness of ODA spending.

2.3. The FCDO must consistently build accountability to the SDGs (Sustainable Development Goals), environmental and human development objectives into all public contracts and take a coherent cross government approach to addressing development challenges. All programmes should have accountability mechanisms built in, this means ensuring multilateral agencies are accountable to their operational partners and the governments and communities they support.

2.4. Under the re-appointment of Andrew Mitchell as Minister of State, the FCDO has improved IATI data sharing and stated that they hope to have all data from recent years publicly available soon, improving transparency and annual reports. However, there are further opportunities to make the UK’s current approach more effective. Policy commitments to mainstream nutrition could be impactful and using the OECD marker more consistently could unlock a greater focus on nutrition-sensitive areas. Both provide an opportunity to increase the quantity and quality of nutrition-sensitive spend. The commitment is an important tool demonstrating a focus on the issue and ensuring accountability is possible.

2.5. Furthermore, Action Against Hunger contributed to the stocktake analysis from ICAN UK, which contains UK Government ODA spending and projects on nutrition interventions. Data was collected from a variety of sources, many provided and funded by FCDO. This openness created an ability to ensure accountability of commitments and created an environment for improved policy decisions. Transparency should be implemented across all UK ODA funded programmes teams across all ODA spending departments.

3. The FCDO or other Government departments’ work with other country donors and multilaterally to work on achieving SDG 2 and food security.

3.1. The FCDO recognises the need for the localisation of ODA delivery partners, but progress is needed to operationalise this commitment, so that local and national partners in countries in crisis have greater decision-making power and autonomy to achieve SDG 2 and food security. This includes increasing the direct access of local and national partners to funding and reducing reliance on multilateral agencies. Donors should learn from each other on how to best reduce the bureaucratic and risk burden on partners and increase their autonomy in decision making. SIDA’s Programmes Based Approach is one model to learn from.  

3.2. The UK should use its position as a major donor to the UN and World Bank to increase their effectiveness in addressing food and nutrition insecurity. Notably, the UK should prioritise enhancing independent oversight of UN agencies to ensure efficient and impactful humanitarian protection and support – something some agencies have been resistant to. The FCDO should work with the World Bank to streamline processes and collaborate with stakeholders to ensure clarity on environmental and social standards from the outset.

3.3. Over 85% of people experiencing crisis or worse level food insecurity live in conflict affected countries[7]. The new White Paper’s dedicated chapter on conflict and food security is therefore welcome. Taking diplomatic action on conflict as the leading underlying driver of hunger and failure to reach SDG2 is vital and we welcome the White Papers commitments on this front. To deliver on the White Paper’s ambition though requires building or re-building expert capacities in embassies, high commissions and at HQ level. Geopolitical tensions are diminishing the influence of international forums like the UN Security Council, leading to an era of impunity with growing disregard for human rights and humanitarian law. The UK must play a role in holding states accountable for violations. Historically, DFID has effectively responded to breaches, prompting states to amend their behaviour, such as reinstating humanitarian access unlawfully denied.

4. The FCDO’s work on achieving food security over the short, medium, and long-term includes its work on food systems, climate resilience, and agricultural sustainability.

4.1. Humanitarian funding must be scaled up separately from climate finance commitments, and funding systems must pivot to flexible, long-term, and anticipatory finance. Through its ODA programmes, the FCDO can also do more to promote joined up approaches between humanitarian, resilience, and peacebuilding actors in Fragile and Conflict Affected States) and greater investment in disaster risk reduction, prevention, early warning systems and anticipatory action to climate disasters and food insecurity crises. This is estimated to cut response costs by up to 85%.

4.2. The UK recently pledged £60mn to the UNFCCC Loss and Damage fund, but this funding isn't additional to existing climate finance commitments. Despite a 2009 commitment to separate international climate finance from Official Development Assistance (ODA), recent practices involve reallocating funds from the ODA budget, revealing issues with creative accounting and double counting. With steep cuts to the ODA budget, the UK needs to scale up financial commitments for the Loss and Damage fund and explore innovative funding sources like a fossil fuel levy outside the ODA budget.

4.3. Moreover, given the impact of climate change on nutrition outcomes, ensuring that climate change adaptation programmes are nutrition-sensitive is paramount for tackling a major cause of malnutrition. Between 2010 and 2021, 17% of FCDO’s programmes with International Climate Financing (ICF) spend were also nutrition related, but only 5% of FCDO’s ICF spend contained nutrition objectives in 2021. We agree with the Independent Commission for Aid Impact (ICAI) who have recommended that the FCDO ensures all agriculture programmes and investments are monitored for nutritional outcomes and have an integral focus on climate change.

4.4. When properly funded and implemented, UK ODA can play a transformative role in achieving food security through agriculture by investing in working with local expertise and promoting agro-ecological farming methods that minimise environmental damage and the dependence of farmers on expensive inputs. The right to land of vulnerable groups and their food and nutrition security must also always be considered in adaptation measures to avoid maladaptation and adverse impacts on vulnerable communities.

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