Document reveals: Adoption agency deliberately circumvented the rules

23 February 2024

The now closed adoption agency DIA knew their employee in South Africa was working double jobs, but they hid the information from the Danish Appeals Board. DIA also acknowledges that the employment was a way of circumventing aid.


Back in December, the Danish Appeals Board suspended all adoption mediation from South Africa. Barely a month later, the Ministry of Social Affairs, Housing and the Elderly also decided to suspend the last five countries from which DIA was still mediating adoptions.Michele Spatari/AFP/Ritzau Scanpix

An employee at the adoption agency Danish International Adoptions (DIA) in South Africa has worked for both DIA and their South African partner, the organization Impilo, which mediates orphans for national and international adoption. 

DIA was aware of the double-dealing, but on several occasions chose not to inform the Danish Appeals Agency. 

The adoption agency also acknowledges that hiring the employee was a way of providing financial support to Impilo after it was decided in January 2022 that it was no longer legal to give it directly to organizations like Impilo.  

This shows a correspondence between DIA and the Danish Appeals Board, which Danwatch has obtained access to. 

DIA's concessions end up being the final straw for the Danish Appeals Board. In mid-December 2023, the Appeals Board suspended all adoptions for South Africa, and at the beginning of the new year, the last five countries from which DIA brokered adoptions were also suspended. 

Social Affairs and Housing Minister Pernille Rosenkrantz-Theil (S) stated in this connection that doubts had been raised as to whether children had come to Denmark legally. 

On the day of the Danish Appeals Agency's and the minister's announcement to DIA, DIA's board took the ultimate consequence and closed.

Worked double jobs throughout the period 

In January, Danwatch could tell that there were many indications that DIA's employee in South Africa worked for both DIA and Impilo. This despite the fact that DIA has previously written to the Danish Appeals Agency that the employee's job at the South African organization ended in spring 2022. 

Among other things, a Facebook post from August 2023 showed that Impilo still highly valued this employee, who also appeared as a contact person on Impilo's website. And in a phone call, the employee confirmed that he was working for the organization again, but had no further comment.  

DIA itself would not comment on whether the employee had worked in both places at the same time. But that is now confirmed by a consultation letter sent on the fourth of December 2023 from DIA to the Danish Appeals Board.

In this, it appears that Impilo wrote to DIA on 16 May 2023 that the employee, who at this time had been employed by the Danish adoption agency for almost a year, also had his time with them.

Just over half a year later, in November 2023, Impilo once again writes to DIA that the employee still works for the organization but is not "involved in children's adoption decisions".

Withheld information

According to Klaus Josefsen, the DIA is obliged to inform about this kind of double work in order to counteract incompatible interests. 

"In an organization like DIA, there can be no doubt that there are clear rules for this sort of thing", he has previously told Danwatch. 

However, that is not what happens. From January 2023 to December 2023, the Danish Appeals Board and DIA write back and forth about the employee's employment, and the Danish Appeals Board not least inquires whether the employee is still employed by Impilo. 

In February, the DIA says that this is not the case, but when Impilo informs the DIA in May that the employee actually works in both places, the DIA does not pass that information on to the Danish Appeals Board. 

Nor do they do so in a consultation response in October, or when Impilo confirms the employee's employment with them in November. Not even if the Danish Appeals Board gives DIA a warning in October and tightens supervision. Only in December does DIA inform about the double job. 

Presented with the new information, Klaus Josefsen now assesses that this is "gross negligence". 

“They are simply withholding information from those who know better. It shows a gross neglect of the rules that they are familiar with and obliged to follow", says Klaus Josefsen. 

Problems with financial aid

DIA's employment in South Africa has also raised other concerns. The Danish Appeals Board not least suspects that DIA is trying to circumvent the rules for financial support. 

In the past, DIA has given support directly to Impilo, but this has not been legal since January 2022. New rules came into effect here, which meant that it is now only possible for DIA to give support if the donor country has a clear law on , how to provide support for adoption work or if the money is given to the responsible authority in the country.

This has not been the case in South Africa, and in the letter to the Appeals Board, DIA writes that the lack of direct support for Impilo has been a problem for the organization because they can no longer help children and their Danish families to the same extent as before. 

DIA's solution will be to employ an Impilo employee to take care of that task, and they therefore conclude that there was indeed "a direct connection between the cessation of support and the employment (...)". Impilo himself writes it more clearly to DIA: "The situation (DIA's employment of the employee from Impilo, ed.) is as it is because DIA could no longer support us directly", it also appears from the letter to the Danish Appeals Board.

The answer is a clear recognition that DIA has circumvented the rules, Klaus Josefsen believes. 

"You can't read it as anything other than that they have, in violation of the rules, channeled money to Impilo and the employee without the authorities, and in that way it is a clear violation of the rules", says Klaus Josefsen. 

The Board of Appeal has roughly the same assessment. In the wake of DIA's letter, the Danish Appeals Board suspends all adoptions from South Africa, because it is no longer certain that DIA's work in the country is carried out in accordance with Danish and international regulations. 

“Extra Grave”

Klaus Josefsen believes that the whole process leaves doubt as to whether DIA has acted out of its own interests. 

"One cannot avoid thinking that one of the actors has made money from this employment. Especially when it comes to double work and the circumvention of financial support", he says and continues: 

"You run the risk of contributing to indirect human trafficking. In that way, it becomes even more serious that in your zeal to mediate adoptions, you grossly disregard the rules that are intended to prevent it". 

Danwatch has presented the criticism to DIA and asked whether they have deliberately withheld information and circumvented the rules for support, but DIA does not want to answer that. 

In the letter from DIA to the Danish Appeals Board, however, they state that DIA has not "followed up in a timely and sufficient manner" on the Danish Appeals Board's concern about the employment relationship and whether it could be in breach of the rules. 

DIA writes that they had the understanding that, without breaking the rules, DIA "could take over the responsibility for the additional support to the families that Impilo previously carried out, as a consequence of the fact that it was no longer allowed to provide adoption-related support to Impilo's work" .

They also write that the "lack of correction of the information about the fact that the employee was also still employed by Impilo is, overall, very regrettable".