In late July 2018, then-president David Platt announced the commencement of a thorough, outside, independent examination of the International Mission Board’s (“IMB”) handling of past matters and its current policies and practices related to its prevention of and response to allegations of physical and sexual abuse of a child (“child abuse”) and sexual harassment (including sexual assault). IMB retained Gray Plant Mooty (“GPM”) to perform the examination. Since being retained, GPM has been conducting a methodical examination of IMB’s past actions and current prevention and response policies and procedures.
Throughout the examination, GPM has provided members of IMB senior leadership and an officer of the Board of Trustees with periodic updates. In April, GPM presented recommendations in detail to all officers of the Board of Trustees. This week, GPM presented an overview of the recommendations to date to the full Board of Trustees.
This statement provides a summary of the work conducted in the examination so far, the work that remains, and GPM’s recommendations to IMB to date.
GPM’s examination consists of two parts: (1) reviewing individual past cases involving allegations of child abuse or sexual harassment (including sexual assault), and determining whether any additional actions are needed as to those individual cases; and (2) making recommendations for changes to IMB’s current policies and practices, considering lessons learned from the review of the individual cases, interviews with key personnel, and a review of current policies.
During the examination, GPM is reviewing all known cases involving allegations of child abuse or sexual harassment (including sexual assault). GPM’s review of individual cases is not limited to any particular time frame and GPM is reviewing cases regardless of whether there was a finding of misconduct. To date, GPM has been given access to any files that the team has requested, including, among other documents, personnel files, appointment files including applications and reference checks, investigation reports, internal communications related to IMB’s response to allegations, and human resources and other support services records.
As GPM reviews individual past cases, GPM has identified whether any actions are needed in each specific matter, such as reporting an allegation to government authorities, following up to ensure victims received care, sending communications to those who had contact with perpetrators, gathering additional information, and conducting investigations. GPM is consulting with other experts as needed during the examination.
GPM has also reached out to victims when the team determined it was necessary to speak with those individuals to complete the examination. In addition, this examination has been made public and, as a result, multiple individuals have reached out to GPM to share their experiences and concerns. GPM and IMB have communicated that the team is willing to speak with any individual who believes they have information relevant to the examination. Out of respect for victims’ privacy and because of the risk that in some instances revisiting these matters may be traumatic, GPM does not plan to affirmatively contact each individual who made an allegation of child abuse or sexual harassment (including sexual assault). Regardless of whether an individual has been contacted as part of the examination, GPM and IMB encourage anyone who has experienced or witnessed child abuse or sexual harassment (including sexual assault) to report those allegations to IMB, and in the case of child abuse or other unlawful conduct, to government authorities.
In the second part of the examination, GPM is making recommendations for changes to IMB’s prevention and response policies and practices going forward. These recommendations are based on the lessons learned from the review of individual cases, including the information provided by those individuals GPM speaks to as part of the review of individual files, along with the review of current policies and interviews with key personnel at IMB.
IMB is a unique organization that places families all around the world, often in remote and isolated locations. Unfortunately, that isolation has the potential to put children at greater risk of abuse. Because of that reality, IMB’s charge to GPM in conducting the examination and making recommendations was not focused on the minimum requirements under the law, but on contemporary best practices for protecting children. Accordingly, GPM’s concerns and recommendations go above and beyond what is legally required and strive to meet the highest standards for keeping children safe.
For similar reasons, GPM’s recommendations related to sexual harassment (including sexual assault) focus not on minimum legal requirements, but on contemporary best practices for prevention and response.
A summary of GPM’s recommendations follows. GPM will continue its work to finalize the recommendations, including revising IMB policies to reflect the accepted recommendations, and will work with IMB to complete remaining actions needed on individual files.
Summary of Conclusions and Recommendations to Date
IMB’s child abuse and sexual harassment (including sexual assault) prevention and response efforts have improved over time. There is, however, much room for improvement if IMB is to meet its goal of adopting best practices for prevention of and response to child abuse and sexual harassment (including sexual assault). GPM has identified a number of significant concerns with IMB’s handling of past cases. Even with the improvements that have been made over time, IMB’s current policies and procedures fall short of contemporary best practice standards.
With those concerns in mind, GPM has concluded that IMB’s prevention and response efforts will be greatly improved by the regular involvement of individuals with expertise in child safety, preventing and responding to child abuse and sexual harassment (including assault), and a trauma-informed approach to prevention and response. Accordingly, GPM is recommending three steps to ensure that those with this expertise are involved in overseeing IMB’s prevention and response efforts.
- Create a new full-time position to oversee prevention and response efforts. This new senior staff member would have a broad range of responsibilities, including overseeing training, receiving reports of child abuse or sexual harassment (including sexual assault), and overseeing the investigation process;
- When IMB receives a report of child abuse or sexual harassment (including sexual assault), involve outside legal counsel with expertise in this area to provide advice throughout the process;
- Continue the current practice of using a forensic psychologist with expertise in interviewing children to conduct investigation interviews of children.
In addition, GPM is recommending an expansive approach to reporting allegations of child abuse to government authorities, going beyond IMB’s legal duties to report. To that end, GPM is making the following recommendations, among others:
- Adopt protocols for consistently reporting allegations of child abuse committed by IMB personnel or others affiliated with IMB to U.S. government authorities, even when there is not a legal duty to do so;
- Adopt protocols for reporting allegations of child abuse to foreign government authorities;
- Revise policies and trainings to make clear that in addition to personnel’s obligations to report suspected child abuse internally to IMB, personnel also have the option, and sometimes the obligation, to report directly to government authorities;
- Report every known incident of alleged child abuse by IMB personnel or others affiliated with IMB that has not previously been reported.
GPM is also making specific recommendations related to many other aspects of IMB’s prevention and response efforts, including the following recommendations:
- Revise the screening process for employees to more thoroughly screen for concerns related to child abuse or sexual harassment (including sexual assault);
- Provide increased training, incorporating additional content, for expanded audiences, and with greater frequency. Topics should include child safety, sexual harassment, sexual assault, and domestic violence, as well as more frequent age-appropriate education for children of IMB personnel to help children recognize and report abuse;
- Implement a consistent, centralized process for screening volunteers including effective oversight from IMB personnel;
- Modify the investigation process to use trauma-informed interview techniques and a trauma-informed approach to weighing evidence;
- Adopt additional policies to enhance the resources and support available to victims during and after the investigation;
- Publicize IMB’s current reference policy to encourage employers considering working or partnering with former IMB personnel to contact IMB to receive accurate information;
- Encourage reporting to IMB leadership when individuals are aware that perpetrators are working in a position that would provide access to children following the end of their affiliation with IMB;
- Adopt a clear process by which IMB will provide affirmative safety warnings when individuals report to IMB leadership that perpetrators are working in a position that would provide access to children following the end of their affiliation with IMB;
- Implement overall changes to policy and practice aimed at eliminating or reducing barriers to reporting and strengthening IMB’s prevention and response efforts.
The focus of all of GPM’s recommendations is the protection of children, as well as adults, from abuse and harassment and responding appropriately when incidents of child abuse or sexual harassment (including sexual assault) do occur to provide care to the victims and ensure accountability for the perpetrators.
IMB has an opportunity to be a leader within the Southern Baptist Convention in prevention and response efforts. GPM’s recommendations will enable IMB to improve its efforts to protect its personnel and their families and those who interact with its personnel and their families and to effectively and appropriately respond when there is an allegation of child abuse or sexual harassment (including sexual assault).