Equality Action Plans - where do you start?


When an organisation faces allegations of discrimination or harassment, particularly when those allegations are in the public eye, the response is often to commit to an equality action plan.  Having such a plan in place is often a requirement for public sector tenders - and increasingly in the private sector too.  It can also form a key plank of an organisation's ESG strategy.  But where do you start?

The first step (and one which is often missed out) is gathering data.  In order to identify priorities and set sensible targets, you first need to gather information about your current position.  This fact-finding exercise should not be limited to gathering diversity data on your current staff (although that's an important element).  Other areas to look at include: 

- Recruitment: looking at the characteristics of your candidate pool and success rates of different groups.

- Career progression and retention: do certain groups become less well-represented at senior levels?  Are attrition rates different for different groups? 

- Pay and benefits: organisations which carry out gender pay gap reporting or voluntary ethnicity or disability pay gap reporting may already have substantial data on this aspect.  Smaller organisations may find the pay banding approach used for gender pay gap reporting to be a useful starting point. 

- Customers, clients and suppliers: as well as looking at diversity from an internal perspective, it may be useful to look outwards at your customer and supplier base.

 - Handling complaints and grievances: one key area is whether staff tend to leave after submitting a grievance.  If so, there may be an issue with your current procedures. 

In many cases, organisations won't have sufficiently robust or detailed data to identify what their focus should be.  Rather than running before they can walk, their first priority should be to put in place mechanisms to gather this information.  This may take many forms, including anonymised diversity monitoring of staff, a qualitative staff survey and customer feedback.  Having this data in place is essential, particularly if the organisation wishes to undertake any positive action for under-represented groups - the data will be crucial in demonstrating the disadvantage suffered by those groups and the proportionality of the steps taken to address it. 

We'll be looking at this issue (and much more) in our inaugural ESG for HR Directors event on 2 November 2023, where we will be joined by guest speaker, Baroness Grey-Thompson DBE DL, a Paralympian and disability rights advocate who will be sharing her experience of implementing equality action plans, including at Yorkshire County Cricket Club in the wake of a racism scandal.  If you would like more information about this event, please contact Jane Amphlett.

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