Norwegian Refugee Council : Internal Displacement Monitoring Centre
17 September 2021
1.1. In this submission, the Norwegian Refugee Council, with Internal Displacement Monitoring Centre, will focus on the following areas of the inquiry: priorities for the UK’s international development strategy and working towards a ‘gold standard’ of best practice for donors.
1.2. The UK’s new international development strategy comes at a time of extraordinary and rising global need, as “the world faces an unprecedented humanitarian crisis resulting from the triple threat of conflict, climate change and Covid-19”.[i] In this context, the need for principled and effective humanitarian assistance is as urgent than ever.
1.3. When funds are stretched, it is even more important that UK aid reaches those who are most vulnerable. Aid should be allocated where needs are greatest in line with humanitarian principles, instead of allocation based on political or economic interests as implied in the Integrated Review.[ii] Given strong and growing links between poverty and state fragility and conflict, the Government should concentrate efforts in fragile and conflict-affected states (FCAS), spending at least half of ODA in such contexts.
1.4. Diplomacy can be a powerful tool to ensure humanitarian assistance reaches those who need it. The IDS should outline how the UK government will leverage its global diplomatic network to support civilians’ access to humanitarian protection and assistance in line with humanitarian principles and International Humanitarian Law (IHL).
1.5. At a time of restricted resources, the Foreign, Commonwealth and Development Office (FCDO) will be able to achieve its greatest impact through: ensuring quality funding practices and supporting reform of the humanitarian financing system; supporting participation of local actors; and investing in anticipatory action as well as solid data and evidence.
1.6. Quality humanitarian financing is vitally important to ensure that scarce resources are used to their greatest potential in saving lives and supporting communities. Humanitarian financing should be flexible, transparent, predictable, and multi-year in line with the UK’s Grand Bargain commitments. The UK should take steps to ensure quality funding elements are maintained as funds are cascaded through the funding chain, particularly through multilateral partnerships.
1.7. FCDO has taken some steps to strengthen and promote localisation. The IDS should build on what has been achieved to ensure policy coherence and engage a range of partners to: increase the flow of funds directly to local and national actors; adopt an approach of risk-sharing with partners; and ensure meaningful participation of people receiving aid in decision-making.
1.8. The humanitarian financing system is still almost entirely reactive to crises. To support better anticipation of and preparedness for disasters, FCDO should work with International Financial Institutions (IFIs), further invest in data and evidence, and support mechanisms with early warning capacities.
2.1. A record 1 in 33 people worldwide need humanitarian assistance – amongst the highest in living memory. [iii] More than 82 million people have been forcibly displaced from their homes as a result of conflict or persecution.[iv] Over 30 million new displacements were recorded in 2020 alone due to weather related disasters, with climate change likely to drive increased displacement in future.[v] Moreover, 95 per cent of all conflict and violence induced displacement happened in countries vulnerable or highly vulnerable to climate change.[vi]
2.2. The Norwegian Refugee Council (NRC) is an independent humanitarian organisation helping people forced to flee violence and disasters in more than 30 fragile and conflict-affected countries. Funding from the UK Government has allowed NRC to support hundreds of thousands of displaced people in 13 countries with humanitarian activities including emergency food assistance, clean water, legal aid and education. Beyond direct implementation, NRC has a prominent role in over 100 cluster and humanitarian co-ordination groups, at global, regional, and national levels, which has allowed for observation of the broader contributions of UK aid in saving lives and helping communities recover from war and disasters. The Internal Displacement Monitoring Centre (IDMC) was established in 1998 as part of NRC, and is the world's definitive source of data and analysis on internal displacement. IDMC has contributed to this submission.
3.1. Prioritising humanitarian response
3.1.1. The UK has a proud history as a global leader in humanitarian response and as one of the world’s largest humanitarian donors.[vii] Between 2015 and 2020 DFID reached 33.7 million people with humanitarian assistance (including food aid, cash and voucher transfers).[viii]
3.1.2. The scale of humanitarian need worldwide is growing, and this assistance and expertise are needed more than ever. A record 235 million people are estimated to need humanitarian assistance and protection in 2021. This represents a near 40 per cent increase since last year, which was already the highest figure in decades.[ix] The humanitarian system is severely overstretched as funding fails to keep pace with rising need. Over each of the past five years, UN-led humanitarian funding appeals for crisis countries have on average faced 40 per cent shortfalls.[x] Families living in fragile and conflict-affected states (FCAS) are particularly badly impacted. For examples, in crisis countries such as Yemen and Syria, recent donor conferences failed to raise even half of the funds needed to support those requiring urgent assistance.
3.1.3. NRC welcomes the UK Government’s commitment to prioritise humanitarian preparedness and response in their future strategy. As argued by the former Secretary of State for International Development, urgent action to support those facing humanitarian crisis is needed “to avert untold tragedy”.[xi]
3.1.4. Humanitarian protection interventions in FCAS also represent vital means to unlocking the potential of other aid programmes in these countries. For example, the UK Government’s goal to support girls’ education cannot be realised if girls cannot attend school safely. Historically, DFID has been a leading supporter of other protection activities such as information, counselling and legal assistance (ICLA). These types of activities can be vital to ensure displaced people are for example able to safely obtain the official documents needed to securely access essential services such as healthcare and education. The FCDO has already announced a series of funding cuts which have servely impacted on the delivery of these types of protection activities, for example in western Africa, the Middle East and elsewhere. This will have a knockon effect on the FCDO’s ability to deliver core goals.
3.2. The importance of humanitarian principles
3.2.1. As recognized by the UK Government in its Humanitarian Reform policy, upholding the core Humanitarian Principles – humanity, neutrality, impartiality and independence – as well as International Humanitarian, Refugee and Human Rights laws, is essential to effective humanitarian action.[xii] Furthermore, as noted in the 2020 UK Government Approach to the Protection of Civilians in Armed Conflict, “Disregard for international law and the humanitarian principles… exacerbates conflict and undermines global stability”.[xiii]
3.2.2. NRC therefore welcome the Prime Minister’s commitment, outlined in the Integrated Review, (IR) to “continue to champion International Humanitarian Law and humanitarian access, and provide principled humanitarian assistance at moments of crisis”.[xiv] However, NRC are concerned by government statements that aid will focus on where ‘development, security, and economic interests align’[xv] rather than on where needs are greatest. This exacerbates an existing trend; as a result of increasing focus on ‘national interest’, the Principled Aid Index by the Overseas Development Institute (ODI) shows that the UK has fallen from the most principled OECD DAC donor in 2015 to 10th in the most recent ranking.[xvi]
3.2.3. In allocating future aid budgets, the FCDO should demonstrate its unqualified commitment to Humanitarian Principles. This is critical to reaching the UK’s goal to protect 20 million people from catastrophic famine. Demonstrating that the allocation of the UK’s humanitarian funding is driven by need, and not compromised by other agendas, has several benefits. Firstly, it will increase the ability of humanitarians to deliver assistance in challenging contexts by maintaining safety and access for frontline responders. Perceived or actual politicisation of humanitarian assistance puts the lives of aid workers, particularly local aid workers, at risk and prevents aid from reaching some of the most vulnerable people in hard to reach lcoations. Secondly, such efforts will promote the UK’s reputation as a global leader in humanitarian action, entailing significant soft-power benefits. The FCDO’s new IDS is an opportunity to concretely outline how the UK Government will ensure that its humanitarian aid is provided in a manner which is consistent with the Principles of Good Humanitarian Donorship and Humanitarian Principles.[xvii]
3.2.4. In order to ensure effective implementation of its new aid strategy, the FCDO should aim to ensure greater policy coherence across different government departments and within its own policies and frameworks – including outlining how potential tensions will be resolved when these impact negatively on its ability to uphold humanitarian principles. Whilst there are benefits to developing synergies and complementarity across the FCDO’s humanitarian, stabilisation, peacebuilding and development approaches, it is important to maintain a fundamental distinction between humanitarian activities and other objectives. For example, the FCDO should retain separate funding streams and independent decision-making for humanitarian action and continue to prioritise meeting lifesaving needs rather than serving other objectives.
3.3. Focus on Fragile and Conflict Affected States (FCAS)
3.3.1. As outlined in the Integrated Review, “To 2030, conflict and instability will remain prevalent and may increase… especially in fragile states.”[xviii] State fragility and conflict are strongly linked with poverty. While economies free of fragility and conflict are proving successful in reducing extreme poverty, economies affected by fragility and conflict show opposite trends, meaning that global poverty is becoming increasingly concentrated in economies in FCAS.[xix] If current trends persist, FCAS may host up to 60 percent of the world’s poor by 2030, despite comprising little over 10 percent of the global population.[xx] Therefore, as argued by the World Bank, “To end extreme poverty by 2030, as pledged under the first Sustainable Development Goal, the global community must focus on economies in FC[A]S.”[xxi]
3.3.2. As the Government is “committed to the global fight against poverty, [and] to achieving the SDGs by 2030”,[xxii] there is clear evidence of a need to concentrate ODA resources in FCAS to meet this agenda. The IDS represents a clear opportunity to reaffirm the UK’s commitment to spending at least half of ODA in FCAS, in line with past practice,[xxiii] recommendations[xxiv] and in accordance with these goals.[xxv]
3.3.3. Leveraging the full toolbox of the FCDO in FCAS also requires innovative thinking to allow development funding, including via International Financial Institutions (IFI), to effectively reach populations most in need in crisis settings, also in situations where UK or international sanctions or policies may complicate engagement with governmental bodies such as in Afghanistan or Myanmar.
3.4. Promoting humanitarian access, respect for IHL and Protection of Civilians
3.4.1. The G7 recently reaffirmed that; “Humanitarian access must be guaranteed, International Humanitarian Law (IHL) respected, [and] civilians… protected”.[xxvi] As a global leader in diplomacy with the world’s fourth largest diplomatic network and seats in all major multilateral organisation including on the UN Security Council, the UK has both “global responsibilities” and significant influence.[xxvii] NRC welcomes the UK’s intention to use this “combined power of diplomacy and development” to be a force for good in tackling root causes of vulnerability and in support of the delivery of principled humanitarian assistance and protection.[xxviii]
3.4.2. The FCDO’s updated approach on the Protection of Civilians[xxix] will play an important role in responding to challenges facing civilians in conflict. Past reviews, including by the Independent Commission for Aid Impact (ICAI), called for closer work between DFID and the FCO in support of promoting humanitarian access and the protection of civilians in line with international law. The creation of the FCDO, and the focus of the Integrated Review on joined-up Government approaches, represent opportunities to deliver on these recommendations.
3.4.3. The IDS should outline how the combined weight of the UK’s global diplomatic network can be operationalised to support civilians’ access to humanitarian protection and assistance in line with humanitarian principles and IHL. In 2019, 90 per cent of humanitarian access incidents which prevented aid agencies from reaching people in need were a result of national government bureaucratic impediments, not conflict or security incidents.[xxx] Diplomacy can therefore be a powerful tool to ensure humanitarian assistance reaches those who need it.
3.4.4. The UK Government can have a significant impact when it uses its full range of diplomatic and aid tools to press for positive humanitarian outcomes. Such integrated interventions have helped mitigate further crises and have demonstrated how the UK can further the goals of aid programmes via diplomatic action. To give some examples: The UK played a leading role in agreeing UN Security Council Resolutions (UNSCR/ 2139 and UNSCR/2165) which promoted cross-border humanitarian access into Syria; The UK-hosted conference on the Future of Syria delivered tangible benefits to Syrian refugees across the Middle East; Outside the Middle East, the UK Government’s diplomatic efforts played a key role in, for example, preventing famine in Somalia in 2017; Currently, UK-supported humanitarian diplomacy in Nigeria and the wider Sahel sun-region is helping to secure improvements in civil-military coordination and humanitarian access.
3.4.5. The UK can further support principled humanitarian action through the systematic inclusion of humanitarian safeguards in sanctions and counter-terrorism frameworks.[xxxi] Sanctions and counter-terrorism regulations can, for example, limit the ability of organisations to implement programmes according to needs alone, impact operational independence and encourage financial derisking measures by banks which can restrict NGOs ability to implement humanitarian activities.[xxxii] As noted by the Independent Reviewer of Terrorism Legislation Jonathan Hall QC, in UNSCR/2462, “the UN Security Council noted for the first time in resolutions adopted under Chapter VII the risk that counter-terrorist financing and counter-terrorism measures might impede “exclusively humanitarian activities” and urged states when designing and implementing such measures to take into account the potential impact of those measures.”[xxxiii] UK Government policies should consider these risks and include appropriate humanitarian safeguards in legislation, such as humanitarian exemptions or licenses, to mitigate restrictions to NGO operations, and ensure that where these exist, they are implemented. The UK should also use its international influence and reputation as a supporter of principled humanitarian action to engage on this issue within the UN Security Council, the G7, and in its bilateral relations with other governments, including authorities in FCAS.
4.1. The principles of Good Humanitarian Donorship[xxxiv] and the Grand Bargain[xxxv] have outlined some of the ‘gold standards’ which donors should aspire to and the UK has committed to. This section outlines some of the areas which NRC sees as urgent priorities. At a time of restricted resources, FCDO will be able to maximise impact through:
4.2. Quality funding
4.2.1. The humanitarian financing system is under enoumous strain and requires an overhaul of its efficiency and effectiveness measures. Continued UK leadership is instrumental to agreeing and implementing the changes needed. NRC, together with Development Initiatives (DI) and the UN Food and Agriculture Organisation (FAO), have reviewed existing funding mechanisms and recommended areas where they can enhance the efficiency and effectiveness of humanitarian responses.[xxxvi] The recommendations specifically point to the need for more predictable, multi-year flexible funding[xxxvii] which can allow implementers to plan and move funding between years, budget lines and across geographical borders to adapt to changing contexts.
4.2.2. The provision of multi-year funding and flexibility are key achievements of the UK’s ODA spending, in line with Grand Bargain and other commitments. In 2020 the UK government allocated over 73 percent of its humanitarian funding directly to UN and Red Cross/ Red Crescent agencies.[xxxviii] However, the flexibility allowed by the UK in these funding allocations has not always filtered down to the UN’s own NGO implementing partners – including local organisations. More needs to be done to ensure the transparency and traceability of the financing chain, as well as the cascading of flexibility measures to implementing partners. A study conducted by NRC and Development Initiatives (DI) in Jordan and Lebanon found that a critical mass of predictable funding is required to transform a humanitarian response, which cannot be achieved without implementers passing on multi-year, flexible funding to downstream partners.[xxxix]
4.2.3. As part of the FCDO’s commitment to maximise value for money (VfM), it should:
4.2.4. Multi-year and flexible funding
126.96.36.199. In line with commitments under the Grand Bargain.”[xl] and recognition of the long-term and complex nature of protracted crises, DFID introduced multi-year humanitarian funding (MYHF) in 2014. With multi-year business cases in most countries of operation, DFID was able to make bilateral grant agreements with NGOs over two or more years. The predictability of these timeframes supports VfM, by for example ensuring reduced costs (including more effective bulk procurements and reduced administrative costs) and more effective action as a result of staffing stability, continuity of services and greater trust in communities.
188.8.131.52. A review by the International Rescue Committee (IRC) found that comparing similar cash transfer programmes – one short-term and one long-term in Somalia – showed efficiency gains of forty-four per cent for the longer-term programme costs.[xli] The report also found that cross-cutting issues, such as the empowerment of women and girls, benefitted from multi-year programming. Additionally, in protracted crises, multi-year agreements can be important mechanisms to facilitate preparedness and resilience-building, such as the UK grant to the Building Resilient Communities in Somalia (the BRCiS consortium).[xlii]
184.108.40.206. While the UK has been a leader in multi-year funding, NGO grants are still typically not flexible. The former DFID’s ‘Programme Partnership Arrangements’ offered multi-year, flexible funding through “strategic level agreements based around mutually agreed outcomes”. These were acknowledged by DFID to enable NGOs “to better plan and deliver programmes, including in more difficult, higher risk environments”,[xliii] but have been discontinued. Under current FCDO grant procedures[xliv] for project-based funding, grants are tightly earmarked, with all budgetary changes needing to be approved in writing in advance. Moving funds between financial years is especially challenging due to the FCDO management systems to meet ODA targets.
220.127.116.11. The UK Government’s initial response to Covid-19 further demonstrated the advantages of adopting greater flexibility and decentralized, rapid decision making to adjust grants and contracts.[xlv] These measures are still necessary, and we urge FCDO to work towards expanding such measures and integrating them into standard operating procedures.
18.104.22.168. Other donors are successfully adopting new ways to ensure flexible funding directly to NGOs. Both the Swedish International Development Cooperation Agency (Sida) and the Norwegian Ministry of Foreign Affairs (NMFA) are adopting programme-based approach (PBA) funding. This provides funding earmarked only to country programme level, enabling the delivery of an integrated package of activities across a variety of sectors and themes.[xlvi] A review of this approach has demonstrated its benefits in enabling NGO partners to deliver “more accountable and needs-based response” through shifting funds towards emerging priorities, addressing over-looked needs, responding to changing circumstances and also changed understandings of what works.[xlvii]
4.2.5. Cascading quality funding to frontline implementers
22.214.171.124. As recognised by ICAI, the UK has consistently provided multiannual core funding to UN humanitarian aid agencies bodies, enabling better planning, investment in organisational capacity, and flexible response to emergencies.[xlviii] The UK has leveraged this support to encourage better accountability and performance by these bodies, including through the Multilateral Aid Review process. Additionally, the UK has used its leverage as a major funder to the UN system to improve global humanitarian practice. This includes using core funding strategically to “build up the coordination and leadership role of the Office for the Coordination of Humanitarian Affairs (OCHA)” and to encourage more donors to support the Central Emergency Response Fund (CERF).[xlix]
126.96.36.199. However, while DFID’s humanitarian reform agenda was effective in encouraging better performance by UN agencies, a significant gap in this was the “role played by the UN in subcontracting non-government organisations (NGOs)”, which “lacks visibility”.[l] Funding from the recipient UN bodies to their implementing NGO partners is typically cascaded in shorter-term cycles and tightly earmarked. A study of pass-through funding conditions by the NGO Forum in South Sudan drew comparison between the restrictions UN agencies placed on NGO project funding compared to those which it implemented in its own activities. [li] This was seen to hamper quality and safe programming as essential support costs were restricted. A DFID funded evaluation has also found that the VfM of MYHF programmes was inhibited where first-tier multilateral recipients did not pass on the multi-year benefits to sub-grantees.[lii]
188.8.131.52. This remains a challenge and one that should be a priority for the FCDO to address in its multilateral partnerships. FCDO should consider measures such as the reporting of pass-through funding, to ensure greater transparency and traceability of funds.
4.2.6. Supporting timely funding to frontline actors
184.108.40.206. Funds cascaded from the UN to NGOs can take over six months to reach frontline actors.[liii] During the early COVID-19 response in 2020, NGOs typically struggled to raise funds. It is therefore imperative to ensure mechanisms for funding to be rapidly distributed to frontline NGOs, including national and local organisations, to ensure timely response.
220.127.116.11. As the response to Covid-19 demonstrated, maintaining a crisis modifier can allow for rapid disbursement during an emergency. The UK Government’s Rapid Response Fund (RRF) proved a vital mechanism for expediting funding, however the total of £18 million was limited compared to other channels.[liv] The crisis reserve should be retained, utilised more frequently and expanded.
18.104.22.168. Mechanisms such as the Country Based Pooled Funds (CBPFs), which are typically pre-primed with funds, and have pre-agreed and transparent decision-making processes, are able to disburse funding directly in a relatively rapid and flexible manner to frontline actors. In response to COVID-19, CBPFs began providing allocations in February 2020, with quick disbursement processes and more flexible arrangements for grant recipients.[lv] In 2020 the UK was the second biggest funding contributor to CBPFs,[lvi] and has been an effective champion for the mechanism through the working group. Funding appears to be falling rapidly with aid cuts (from $320m in 2019 to $182m in 2020, to just $72m so far in 2020[lvii]) and NRC encourages FCDO to reverse this trend. CBPFs are designed to ensure the assistance they provide is locally appropriate and allows for quick response that promotes the country-level coordination of humanitarian assistance. Additionally, the recent pilot in the Sahel of utilising the CERF to make grants directly to NGOs, via IOM, showed further opportunities for innovating existing mechanisms.[lviii]
22.214.171.124. To further this agenda beyond reliance on pooled fund mechanisms, the UK can play a leading role in the upcoming review of the Inter-agency Standing Committee structure. The UK should embrace existing recommendations to review the way funding flows through first level recipients and ensure that transparency and efficiency are a primary consideration.
4.3. Localisation and participation of affected populations
4.3.1. In the Grand Bargain, signatories committed to “making principled humanitarian action as local as possible and as international as necessary”.[lix] In order to improve the accountability, efficiency, impact and sustainability of the humanitarian sector, there needs to be a more equitable distribution of power to the benefit of people living in affected communities.[lx]
4.3.2. FCDO has taken some steps to strengthen and promote localisation over recent years. The new IDS should build on what has been achieved to ensure policy coherence and engage a range of partners. In particular FCDO should:
4.3.3. Channelling support to local and national actors
126.96.36.199. Local actors, including national NGOs, work at the frontline of humanitarian response and are often critical to programme delivery. NNGOs typically offer strong contextual awareness, a deep knowledge of culture and language, as well as well-established and trusted relationships with communities and other local actors.
188.8.131.52. In the Grand Bargain, signatories committed “to achieve by 2020 a global, aggregated target of at least 25 per cent of humanitarian funding to local and national responders as directly as possible to improve outcomes for affected people and reduce transactional costs.”[lxi]
184.108.40.206. A practical route for the FCDO to move towards this goal would be to scale-up support to existing country-level and regional platforms, consortia and funding instruments with clear plans to foster local leadership of crisis response. Existing mechanisms include, for example, the Start Fund, LIFT and HARP funding[lxii] in Myanmar and CBPFs. All mechanisms should consider principles of quality funding - in particular multi-year, flexible funding - to local responders.
4.3.4. Moving from ‘risk-transfer’ to ‘risk-sharing’
220.127.116.11. Progress on localization, and in particular on the direct transfer of resources to local and national actors, requires seeing them as true partners rather than sub-contractors. It also requires careful consideration of policies related to risk management/sharing. FCDO has recently taken positive steps to factor localization expectations into humanitarian funding guidelines for NGOs, for example by including a consistent, fair approach to support overheads costs for downstream partners.[lxiii] However, such an approach is not taken consistently across FCDO grants and contracts, and the FCDO’s prevailing approach is of a significant compliance burden and risk-transfer to the grant or contract recipient.
18.104.22.168. The UK Government should also consider seriously the role of the intermediary to support them to involve local actors in decision-making, including in relation to programme design, prioritization processes, adaption of due diligence requirements and risk analysis. As UN agencies continue to play the most prominent intermediary role, the UK should use its influence to ensure the UN further develops harmonized and simplified processes, in consultation with local NGOs.
4.3.5. Ensuring meaningful participation of recipients of aid
22.214.171.124. Localisation needs to go beyond financial targets and token contribution of national actors to ensure meaningful participation of civil society and affected communities in decisions affecting them.
126.96.36.199. National and local civil societies should be involved as equal or lead partners in the design of programmatic partnerships and consortia, instead of being seen purely as sub-contractors to their international ‘intermediary’ partners (UN agencies and INGOs). FCDO programme design processes should also systematically engage affected populations to understand their needs and opinions through proactive consultation and collaboration.
188.8.131.52. Other forms of local community and local government leadership should also be mapped and reviewed, with humanitarian principles shaping the nature of partnerships with these actors.[lxiv]
4.4. Anticipation, preparedness, mitigation and prevention
4.4.1. The humanitarian financing system is still almost entirely reactive. Less than one percent of funding is currently available for anticipatory action[lxv] despite increasingly clear linkages between climate change and disasters [lxvi][lxvii]
4.4.2. Data and evidence can help inform not only anticipatory action but also disaster prevention, preparedness and response. Humanitarian and development actors can adequately anticipate crises if they know where and when disasters are likely to strike, how many people will be impacted and what their vulnerabilities are. Yet, data is difficult to obtain in certain contexts or else limited to numbers. Innovative data monitoring can help close some of these gaps and FCDO should consider further investing in efforts to collect and consolidate disaggregated data and evidence. Risk modelling and forecast models can, for their part, help predict future crisis and their humanitarian impact.
4.4.3. Anticipation, preparedness and prevention offer value for money and need to be carefully balanced with response funding. The UK’s response in support of the Government of Ethiopia to a drought resulting from El Niño effect in 2015-16 was critical in averting a famine and provided evidence that the early response resulted in significant savings over the estimated cost of a later response. [lxviii]
4.4.4. In order to better anticipate crises, it is vital that donors further invest in early warning and preparedness capacities. Some existing mechanisms offer the chance to do this – for example pre-agreed funding through CERF’s rapid response funding window for anticipatory action allows for the anticipation of crises such as epidemics or droughts. Recent pilots in Bangladesh (flooding), Chad (drought), Ethiopia (drought) and Malawi (drought) are growing the evidence base further. NRC encourages the UK to continue support to mechanisms such as CERF, and to demonstrate leadership in encouraging an expansion of the anticipatory action agenda.
4.4.5. As recognised in the former DFID Humanitarian Reform Policy, working with International Financial Institutions will be essential to change this.[lxix] Working with IFIs in FCAS offers further opportunities to build capacity to anticipate, prepare for and mitigate disasters, including climate-related risks. NRC therefore welcomes the World Bank (WB), International Monetary Fund’s (IMF) and African Development Bank (AfDB) development of tailored strategies for engaging FCAS. [lxx][lxxi]
4.4.6. As the IFIs develop these strategies, NRC would welcome the FCDO’s support in ensuring greater engagement between IFIs and humanitarian organisations in FCAS. Currently the IFIs struggle to engage adequately with NGOs, who often have valuable relationships, skilled staff, and on-the-ground presence to provide valuable information on the local context. NRC would encourage the IFIs to develop processes for more systematically engaging with NGOs - specifically in areas such as protection and conflict analysis – as well as operational partnerships where specialised actors are better able to deliver, such as in active conflict situations.
[i] FCDO (2021) ‘G7 famine prevention and humanitarian crises compact’, 5 May 2021, London. (online) Available at: <https://www.gov.uk/government/publications/g7-foreign-and-development-ministers-meeting-may-2021-communique/g7-famine-prevention-and-humanitarian-crises-compact>
[ii] Cabinet Office (2021) ‘Global Britain in a Competitive Age, the Integrated Review of Security, Defence, Development and Foreign Policy’ (online) Available at: <https://www.gov.uk/government/publications/global-britain-in-a-competitive-age-the-integrated-review-of-security-defence-development-and-foreign-policy>
[iii] OCHA (2020) ‘Global Humanitarian Overview 2021’ (online) Available at: <https://gho.unocha.org/>
[iv] UNHCR (2021) ‘’UNHCR Figures at a Glance’ (online) Available at: <https://www.unhcr.org/uk/figures-at-a-glance.html>
[v] IDMC (2021) ‘Global Report on Internal Displacement 2021: Internal displacement in a changing climate’ (online) Available at: <https://www.internal-displacement.org/sites/default/files/publications/
[vii] DFID (2017) ‘Saving lives, building resilience, reforming the system: the UK Government’s Humanitarian Reform Policy’ (online) Available at: <https://assets.publishing.service.gov.uk/government/uploads/system/
[viii] DFID (2020) ‘DFID Results Estimates 2015-2020: Sector Report’ (online) Available at: <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data
[ix] OCHA (2020) ‘Global Humanitarian Overview 2021’ (online) Available at: <https://gho.unocha.org/>
[x] Lowcock, M. (2021) What’s wrong with the humanitarian aid system and how to fix it. Remarks by the Under-Secretary-General for Humanitarian Affairs, Mark Lowcock, at the Center for Global Development on Proposal for an Independent Commission for Voices in Crisis. 22 April 2021 (online) Available at:
[xi] Patel, P. (2017) Foreword. ‘Saving lives, building resilience, reforming the system: the UK Government’s Humanitarian Reform Policy’, by DFID (online) Available at: <https://assets.publishing.service.gov.uk/
[xii] DFID (2017) ‘Saving lives, building resilience, reforming the system: the UK Government’s Humanitarian Reform Policy’ (online) Available at: <https://assets.publishing.service.gov.uk/government/uploads/system/
[xiii] DFID, FCO and MoD (2020) “UK Approach to Protection of Civilians in Armed Conflict” 27 August 2020. (online) Available at: <https://www.gov.uk/government/publications/uk-paper-on-the-approach-to-protection-of-civilians-in-armed-conflict/uk-approach-to-protection-of-civilians-in-armed-conflict>
[xiv] Cabinet Office (2021) ‘Global Britain in a Competitive Age, the Integrated Review of Security, Defence, Development and Foreign Policy’ (online) Available at: <https://www.gov.uk/government/publications/global-britain-in-a-competitive-age-the-integrated-review-of-security-defence-development-and-foreign-policy>
[xv] Raab, D. (2020) ‘Letter from the Foreign Secretary regarding the future of the UK aid budget’ 82 December 2020 (online) available at: <https://committees.parliament.uk/publications/3683/documents/38142/default/>
[xvi] ODI (2020) https://odi.org/en/press/rich-countries-risk-national-interest-through-short-sighted-aid-policies-odi-research/
[xvii] Good Humanitarian Donorship (2018) ‘24 Principles and Good Practice of Humanitarian Donorship’ (online) Available at: <https://www.ghdinitiative.org/ghd/gns/principles-good-practice-of-ghd/principles-good-practice-ghd.html>
[xviii] Cabinet Office (2021) ‘Global Britain in a Competitive Age, the Integrated Review of Security, Defence, Development and Foreign Policy’ (online) Available at: <https://www.gov.uk/government/publications/global-britain-in-a-competitive-age-the-integrated-review-of-security-defence-development-and-foreign-policy>
[xix] P. Corral et al. (2020) ‘Fragility and Conflict: On the Front Lines of the Fight against Poverty’ Washington, DC: World Bank. (online) Available at: <https://openknowledge.worldbank.org/bitstream/handle/10986/33324/
[xxii] Cabinet Office (2021) ‘Global Britain in a Competitive Age, the Integrated Review of Security, Defence, Development and Foreign Policy’ (online) Available at: <https://www.gov.uk/government/publications/global-britain-in-a-competitive-age-the-integrated-review-of-security-defence-development-and-foreign-policy>
[xxiii] DFID and HM Treasury (2015) ‘UK aid: tackling global challenges in the national interest’, November 2015. (online) Available at: <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
[xxiv] DFID and HM Treasury (2015) ‘UK aid: tackling global challenges in the national interest’ (online) Available at: <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/
[xxv] UN (2021) Sustainable Development Goal 16 (online) Available at: < https://sdgs.un.org/goals/goal16>
[xxvi] FCDO (2021) ‘G7 famine prevention and humanitarian crises compact’, 5 May 2021, London. (online) Available at: <https://www.gov.uk/government/publications/g7-foreign-and-development-ministers-meeting-may-2021-communique/g7-famine-prevention-and-humanitarian-crises-compact>
[xxvii] Cabinet Office (2021) ‘Global Britain in a Competitive Age, the Integrated Review of Security, Defence, Development and Foreign Policy’ (online) Available at: <https://www.gov.uk/government/publications/global-britain-in-a-competitive-age-the-integrated-review-of-security-defence-development-and-foreign-policy>
[xxix] DFID, FCO and MoD (2020) ‘UK Approach to Protection of Civilians in Armed Conflict’ 27 August 2020. (online) Available at: <https://www.gov.uk/government/publications/uk-paper-on-the-approach-to-protection-of-civilians-in-armed-conflict/uk-approach-to-protection-of-civilians-in-armed-conflict>
[xxx] OHCHR (2020) ‘Situation of human rights in Yemen, including violations and abuses since September 2014’ (online) Available at: <https://www.ohchr.org/Documents/HRBodies/HRCouncil/GEE-Yemen/2020-09-09-report.pdf>
[xxxi] NRC (2018) ‘Principles under Pressure: the impact of counterterrorism measures and preventing/countering violent extremism on principled humanitarian action’, 12 June 2018 (online) Available at: <https://www.nrc.no/resources/reports/principles-under-pressure/>
[xxxiii] Hall Q.C., Jonathan (2021) ‘The Terrorism Acts in 2019: Report of the Independent Reviewer of Terrorism Legislation on the Operation of the Terrorism Acts 2000 and 2006’, March 2021 (online) Available at: <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/
[xxxiv] Good Humanitarian Donorship (2018) ‘24 Principles and Good Practice of Humanitarian Donorship’ (online) Available at: <https://www.ghdinitiative.org/ghd/gns/principles-good-practice-of-ghd/principles-good-practice-ghd.html>
[xxxv] IASC (2021) ‘The Grand Bargain’ (official webpage) Available at: <https://interagencystandingcommittee.org/grand-bargain>
[xxxvi] FAO, DI and NRC (2020) ‘Catalogue of quality funding practices to the humanitarian response: A reference tool for policymakers and practitioners to enhance the efficiency and effectiveness of programming (Report, July 2020) (online) Available at: <https://www.nrc.no/globalassets/pdf/reports/catalogue-of-quality-funding-practices/catalogue-of-quality-funding-practices-to-the-humanitarian-response_report.pdf>
[xxxvii] IASC (2021) ‘Enhanced quality funding (Increase collaborative humanitarian multi-year planning and funding and reduce the earmarking of donor contributions)’ (official webpage) Available at: <https://
[xxxviii] FTS (2021) ‘United Kingdom, 2020: Donor Data’ Available at: <https://fts.unocha.org/donors/2917/
[xxxix] NRC and DI (2019) ‘Field perspectives on multi-year humanitarian funding and planning: How theory has translated into practice in Jordan and Lebanon’, December 2019 (online) Available at: <https://www.nrc.no/
[xl] IASC (2021) ‘Enhanced quality funding (Increase collaborative humanitarian multi-year planning and funding and reduce the earmarking of donor contributions)’ (official webpage) Available at: <https://
[xli] IRC (2020) ‘A WIN-WIN: Multi-year flexible funding is better for people and better value for donors’ (online) Available at: <https://www.rescue.org/report/win-win-multi-year-flexible-funding-better-people-and-better-value-donors>
[xlii] FAO (2017) ‘Living up to the promise of multi-year humanitarian financing’ (online) Available at: <https://www.nrc.no/globalassets/pdf/reports/living-up-to-the-promise-of-multi-year-humanitarian-financing/living-up-to-the-promise-of-multi-year-humanitarian-financing_v2.pdf>
[xliii] DFID (2013) ‘Programme Partnership Arrangements 2011-2014’, The National Archives, archived 2 January 2013 (online) Available at: <https://webarchive.nationalarchives.gov.uk/ukgwa/20130102204346/
[xliv] Most FCDO grants are still governed by the former DFID template, which can be found here.
[xlv] ICAI (2020) ‘UK aid spending during COVID-19: management of procurement through suppliers’ Information note, December 2020 (online) Available at: <https://icai.independent.gov.uk/wp-content/uploads/ICAI-info-note_UK-aid-spending-during-COVID-19_management-of-procurement.pdf>
[xlvi] NRC (2020) ‘The Programme Based Approach: 10 lessons’ (online) Available at: <https://www.nrc.no/globalassets/pdf/reports/the-programme-based-approach/10-lessons-pba-funding-nrc-july-2020.pdf>
[xlviii] ICAI (2018) ‘The UK’s approach to funding the UN humanitarian system: a performance review’ December 2018. (online) Available at: <https://icai.independent.gov.uk/wp-content/uploads/ICAI-Humanitarian-Reform-Report-2.pdf>
[l] ICAI (2018) ‘The UK’s approach to funding the UN humanitarian system: a performance review’ December 2018. (online) Available at: <https://icai.independent.gov.uk/wp-content/uploads/ICAI-Humanitarian-Reform-Report-2.pdf>
[li] South Sudan NGO Forum (2018) ‘Cost efficiency discussion paper’ (online) Available at: <https://gblocalisation.ifrc.org/wp-content/uploads/2019/03/NGO-Forum-Cost-Efficiency-Discussion-Paper.pdf>
[lii] Cabot Venton, C., Sida, L. (2017) ‘The Value for Money of Multi-Year Humanitarian Funding: Emerging Findings’ Valid International, Oxford (online) Available at: <https://assets.publishing.service.gov.uk/media/
[liv] ICAI (2020) ‘UK aid spending during COVID-19: management of procurement through suppliers’ Information note, December 2020 (online) Available at: <https://icai.independent.gov.uk/wp-content/uploads/ICAI-info-note_UK-aid-spending-during-COVID-19_management-of-procurement.pdf>
[lv] NRC (2020) ‘Make or break – the implications of Covid-19 for crisis financing’ (online) Available at: <https://www.nrc.no/resources/reports/make-or-break--the-implications-of-covid-19-for-crisis-financing/>
[lvi] IRC (2021) ‘Focus on the Frontlines: How the Grand Bargain can deliver on its promise to improve humanitarian aid’ (online) Available at: <https://www.rescue.org/report/focus-frontlines-how-grand-bargain-can-deliver-its-promise-improve-humanitarian-aid>
[lvii] OCHA (2021) Pooled Funds Data Hub (online) Available at: <https://pfdata.unocha.org/?fund=cbpf&chart
[lviii] OCHA (2020) ‘UN humanitarian chief releases $25M in CERF funding to IOM for NGO COVID-19 response’, 23 June 2020 (online) Available at: <https://www.unocha.org/story/un-humanitarian-chief-releases-25m-cerf-funding-iom-ngo-covid-19-response>
[lix] Barbelet, V. G (2018) ‘As local as possible, as international as necessary: Understanding capacity and complementarity in humanitarian action’ HPG Working Paper, November 2018. (online) Available at: <https://cdn.odi.org/media/documents/As_local_as_possible_as_international_as_necessary_understanding_capacity_and_comp.pdf>
[lx] IRC (2021) ‘Focus on the Frontlines: How the Grand Bargain can deliver on its promise to improve humanitarian aid’ (online) Available at: <https://www.rescue.org/report/focus-frontlines-how-grand-bargain-can-deliver-its-promise-improve-humanitarian-aid>
[lxi] IASC (2021) ‘More support and funding tools for local and national responders’, Grand Bargain Official Website (online) Available at: <https://interagencystandingcommittee.org/more-support-and-funding-tools-for-local-and-national-responders>
[lxii] The Start Fund is a multi-donor pooled fund managed by NGOs but supported by donors including the FCDO. It provides rapid financing to underfunded small to medium scale crises, spikes in chronic humanitarian crises, and to act in anticipation of impending crises, filling a critical gap in humanitarian financing. The Livelihoods and Food Security Fund (LIFT) is a multi-donor pooled managed by the United Nations Office for Projects Services (UNOPS) and funded by donors including the FCDO. The Humanitarian Assistance and Resilience Programme (HARP) is an FCDO funded facility focused on incorporating resilience into humanitarian response programming.
[lxiii] FCDO (2021) ‘FCDO Humanitarian Funding Guidelines for NGO’s applying for CHASE Humanitarian Response Funding’ (online) Available at: <https://www.gov.uk/guidance/humanitarian-response-funding>
[lxiv] IASC (2020) ‘Interim Guidance – Localisation and the COVID-19 Response’ May 2020 (online) Available at: <https://interagencystandingcommittee.org/system/files/2020-11/IASCpercent20Interimpercent20Guidancepercent20onpercent20
[lxv] Red Cross EU (2021) ‘Anticipation Hub: striving to make anticipatory humanitarian action the new norm’ (online) Available at: <https://redcross.eu/latest-news/anticipation-hub-striving-to-make-anticipatory-humanitarian-action-the-new-norm/>
[lxvii] DFID (2017) ‘Saving lives, building resilience, reforming the system: the UK Government’s Humanitarian Reform Policy’ (online) Available at: <https://assets.publishing.service.gov.uk/government/uploads/system/
[lxviii] Cabot Venton, C., Sida, L. (2017) ‘The Value for Money of Multi-Year Humanitarian Funding: Emerging Findings’ Valid International, Oxford (online) Available at: <https://assets.publishing.service.gov.uk/media/
[lxix] DFID (2017) ‘Saving lives, building resilience, reforming the system: the UK Government’s Humanitarian Reform Policy’ (online) Available at: <https://assets.publishing.service.gov.uk/government/uploads/system/
[lxx] IMF (2021) ‘Enhancing the International Monetary Fund’s Engagement in Fragile and Conflict-Affected States (FCS): FCS Strategy’ July 30, 2021 (online) Available at: <https://www.imf.org/en/capacity-development/FCS-consultation>
[lxxi] World Bank Group (2020) ‘World Bank Group Strategy for Fragility, Conflict, and Violence 2020-2025’, February 26 2020 (online) Available at: <https://www.worldbank.org/en/topic/fragilityconflictviolence/