Equity, Diversity and Inclusion policy
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Agreed by Board: July 2024
To be reviewed: July 2027
Scope
This Policy applies to all members, trustees, employees (and job applicants) and volunteers of BDEF (Bristol Disability Equality Forum). It also applies to any visitors, contractors or partners working with BDEF e.g. on recruitment, governance, employment or service delivery. Furthermore, it is expected that people using BDEF services will adhere to the principles of the Policy in terms of how they treat staff and other people.
This Policy applies specifically to eliminating less favourable treatment and discrimination and promoting equality of opportunity in respect of people with ‘protected characteristics’ defined in the Equalities Act 2010 as:
- Age
- Disability
- Race/ethnicity/nationality
- Sex
- Religion or cultural beliefs
- Gender reassignment
- Marital status and civil partnership
- Sexual orientation
- Pregnancy and maternity
However, BDEF will also ensure that employees, trustees, members and people who use services do not receive less favourable treatment due to other characteristics, such as class and socio-economic disadvantage, being an unpaid carer, trades union membership, political belief etc.
The Policy applies across the whole range of BDEF’s employment policies and practices, including those relating to discipline, grievance, harassment and complaints, and also to our governance, membership and service delivery.
Aims
To provide a clear statement of BDEF CIO’s (Bristol Disability Equality Forum) commitment and approach to equality, diversity and inclusion.
To align with BDEF’s core value of “Ethical Behaviour”, which includes:
- Promoting equality of opportunity
- Celebrating and value diversity
- Eliminating unlawful direct and indirect discrimination
To outline how BDEF will undertake recruitment of staff and volunteers in a fair and non-discriminatory way and will use positive action where required to make sure people with all protected characteristics have equal access to opportunities.
To outline how staff, volunteers and trustees of BDEF will have access to appropriate support and training in a non-discriminatory way, and how those with protected characteristics will be able to access particular positive action initiatives to progress in the organisation in line with the Equality Act 2010.
To ensure that BDEF creates a working atmosphere in which the contributions and needs of everyone are fully valued and recognised.
To ensure there is a working environment where there is no toleration of any bullying, harassment or victimisation, or violent or abusive behaviour aimed at staff or people using services, and where any incidents are investigated immediately and appropriately addressed.
To support the Equality Act 2010 Public Sector Duty to foster good relations between those who have protected characteristics and those who do not, and to promote community cohesion.
To outline our commitment to being led by Disabled people, employing Disabled staff and promoting peer support, co-production and Disability Equality.
To outline our commitment to the Social Model of Disability and to removing and challenging the barriers that society imposes on Disabled people.
To ensure BDEF does all it can to meet the access needs of Disabled people, whether they are trustees, staff, members, job applicants or people using services (see detail in our separate Access Statement).
To ensure that all everyone who uses BDEF services is treated with respect, and that their cultural, religious, language and other needs are met.
Policy statement
BDEF fully supports the principles of equality and diversity. We aim to promote, value and manage diversity and recognise that talent and potential are distributed across the population.
Whilst we intend for all our staff, members and trustees to be Disabled People, BDEF also recognises intersectionality, and that many Disabled people involved with our organisation may have more than one protected characteristic e.g. a Black older disabled woman. Therefore, we will still work to ensure we have a diverse workforce and trustee profile. We will also work with specialist partner organisations where necessary to improve our practice and to meet their needs effectively.
We believe that not only are there moral and social reasons for promoting equality of opportunity, but it is also in the best interest of this organisation to recruit and develop the best people for our jobs from as wide and diverse a pool of talent as possible. However, we believe that the work we do is best delivered by Disabled people who understand the barriers that members and other people using our services face.
We believe that everyone should be able to achieve their full potential. We realise that we must all take account of the power and privilege that exists in our society, which creates visible and invisible barriers to opportunities, and which manifests as systems and structures which hold people back.
BDEF also recognises that particular groups and individuals in society are oppressed and disadvantaged. We aim to remove any barriers, bias or discrimination that prevents them from realising their potential and contributing fully to our organisation’s performance.
BDEF recognises that Disabled people face discrimination and disadvantage in society, and this is reflected in their economic status, employment and the services they receive. We recognise that discrimination operates through commonly held assumptions and prejudices, which are reinforced by laws, rules and customs (e.g. institutional discrimination). This makes discrimination appear normal and inevitable. We are committed to empowering them to overcome these barriers to achieve equal opportunity.
BDEF recognises that systemic racism and other forms of institutional discrimination exist in most organisations, and so we will work towards developing an anti-racist and anti-discriminatory approach to our governance, employment and service delivery.
BDEF’s commitment to developing anti-discriminatory practice relates to all kinds of discrimination, including:
- Direct discrimination: Where someone is treated less favourably than another because they have a protected characteristic
- Indirect discrimination: When a requirement or a condition is applied which has a detrimental effect on a particular group or individual. This applies even if there was not a deliberate intention to discriminate.
- Associative discrimination: Direct discrimination against someone because they associate with another person who has a protected characteristic.
- Perceptive discrimination: Direct discrimination against someone because others think they have a protected characteristic even if they do not possess that characteristic.
- Harassment: Unwanted conduct related to a protected characteristic which violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for them. This applies even if the conduct is not directed at the individual or if they do not have the protected characteristic.
- Third party harassment: Potential liability for the harassment of staff by others such as clients or customers.
- Victimisation: When someone is treated badly because they have made or supported a complaint under the Equalities Act or it is thought that they have done so.
BDEF also recognises that Disabled people face discrimination due to the legal and benefits system and governmental policy framework, the built and wider environment, inaccessible information provision and other people’s attitudes. We will do all we can to identify, challenge and remove these systemic discriminatory policies and practices.
BDEF will ensure that our recruitment, employment and working practices comply with the obligations of the Equality Act of 2010, and all relevant Codes of Practice. No applicant or worker will be treated less favourably or placed at a disadvantage to another on the grounds set out in the scope.
However, whilst BDEF recognises that compliance with the Equality Act is the basis for a policy, as a Disabled people -led organisation, we need build on this and not just do the minimum required of us legally, but to develop best practice and act as an example to other organisations.
BDEF aims to ensure that employment and progression in the organisation are determined solely by application of objective criteria and personal merit. All working procedures will be kept under review to ensure that individuals are recruited, selected, trained and promoted on the basis of their abilities, merits and requirements of the job.
Positive action will be taken, when necessary, in relation to advertising posts and the services available, and through training to remedy the effects of past discrimination and disadvantage.
BDEF recognises that equality and diversity is equally important to people who use our services. They will be dealt with respectfully and fairly and on the basis of an objective assessment of their presented needs (special training may be given where necessary).
BDEF recognises that to promote inclusion, any organisation needs to change its policies and practice to make them accessible and welcoming, and it is not the Disabled person who needs to change and be ‘integrated’
BDEF recognises it also has a key role in promoting community cohesion and tacking any hate crime or community tensions. It will do that in partnership with key community organisations.
Implementing the policy
Everyone involved with BDEF in any way (e.g. clients, visitors, partners) is expected to take a role in achieving our aims to be anti-racist and anti-discriminatory and to be led by people with lived experience. They should therefore also challenge inequality, discrimination and harassment, and champion best practice.
Ultimate responsibility for agreeing and reviewing the policy will rest with the Board of Trustees. However, it is the responsibility of all Board members to accept personal involvement in practical application of the policy.
Trustees' responsibilities
Trustees will:
- Monitor the implementation of the Policy and review it annually;
- Receive and discuss an annual report of EDI information and statistics on employment and service delivery;
- Ensure that staff and volunteers and trustees are aware of the policy and trained in Equality, Diversity and Inclusion;
- Regularly review other policies and procedures (e.g. recruitment and selection) in the light of legislation and good practice.
Director's responsibilities
Day to day responsibility for implementation and monitoring the effectiveness of this policy will rest with BDEF’s Director.
The Director and any other managers have a particular responsibility to:
- Ensure that staff and volunteers are aware of the policy and trained in Equality, Diversity and Inclusion;
- Ensure the policy is implemented in their management of staff and volunteers;
- Keep themselves up to date with current thinking on EDI through training, reading and other professional development;
- Encourage staff, volunteers and members to learn more about equality, diversity and inclusion;
- Promote a positive, professional work environment in relation to the policy by challenging behaviour, actions or decisions which breach the Policy;
- Proactively develop partnerships with organisations representing groups of people with protected characteristics and taking positive action in developing their services to ensure no groups are under-represented;
- Creating a safe working environment where EDI are regularly discussed and staff, volunteers and members feel safe to address key issues;
- Acting as a role model for others and developing personal skills in order to handle issues relating to dignity at work;
- Effectively manage instances of lack of inclusion that they observe or are reported to them.
Employees and volunteers
All employees and volunteers should:
- Understand the value and benefit of equality, diversity and inclusion;
- Undertake introduction to BDEF’s EDI approach as part of their induction;
- Familiarise themselves with the Policy;
- Draw to the attention of the Director or trustees any instance of perceived discrimination, bullying, harassment or victimisation, or any perceived problem in relation to BDEF’s working practices in relation to diversity;
- Promote the inclusion of members from the widest range of backgrounds in all of its activities;
- Promote good relations between groups with different backgrounds or protected characteristics;
- Challenge and call out inequality, a lack of diversity or inclusion within BDEF, or any other “micro-aggressions”;
- Be willing to accept challenge when they might display non-inclusive behaviours.
An employee or volunteer who believes that they have been treated unfairly and contrary to the intentions of this Policy should raise it through the Grievance Procedure.
If any employee has been found to have acted in breach of this Policy, this will be treated as disciplinary matter.
External people
Any member or person using services or attending events who believes that they have been treated unfairly by BDEF and contrary to the intentions of this policy should raise it through the Complaints Procedure.
Any job applicant who believes they have been treated unfairly and contrary to the intentions of this policy, or any trustee who experiences discrimination should contact the Co-Chairs of BDEF.
Recruitment procedure
All Job Descriptions and Person specifications will be reviewed before a job is advertised to ensure there are no criteria that could constitute direct or indirect discrimination (e.g. requirement for a driving licence). Discriminatory job titles should be avoided.
Any qualifications or requirements applied to job which effectively restrict it to certain applicants (e.g. of one sex) should be kept only if they are justifiable in terms of the job to be done, and the terms of Equality Act of 2010. However, positive action can be taken e.g. including multi-lingualism or cultural competence in the criteria. (The policy of employing only Disabled people is legal positive action under the Equality Act).
Positive action should be taken where possible to try to attract applicants from a range of backgrounds and protected characteristics e.g statements encouraging people from different groups to apply or advertising through equalities organisations.
Each individual should be assessed according to their capability to carry out a given job. For example, it should not be assumed that women or men only will be able to do certain kinds of work, or that disabled people are restricted to a limited number of jobs.
The ability to accept and implement this EDI Policy at a level and in a manner appropriate to the job is a necessary qualification for any job within the BDEF and should be included in Job Descriptions and Person Specifications.
Selecting for appointment must be based strictly on the basis of capacity to fulfil the requirements of the post. No irrelevant factors or attributes, which a potential applicant should possess, should be included in the Job Description or Person Specification.
Advertisements must make clear that the BDEF is an Equal Opportunity Employer and should be displayed in places that do not exclude members of any groups. No irrelevant factors should be included in any advertising material.
Interview panel and shortlisting
An interview panel will be set up for each vacancy as and when necessary. The composition and size of the panel should reflect the diversity of BDEF.
Generally, each interview panel will consist of a representative (s) of the trustees, the Director, and staff and special advisers when appropriate.
Shortlisting prior to the interview may be carried out by the interview panel or BDEF employees with relevant expertise on the role in question. Wherever possible, BDEF will strive to ensure that those shortlisting and interviewing candidates represent the diversity of the City where possible.
Interview procedure
The Chair of the interview panel is responsible for the administrative arrangements of the interview and will ensure interviews are conducted in an accessible venue where they will not be interrupted, and that the access needs of the panel and applicants are met.
Prior to the interview, panel members will discuss the structure of the interview and agree the questions to be asked. There should be some standard questions for all candidates. Questioning should be derived from the job description and skills and aptitudes required and education and experience offered on the application (form).
The interview panel should not discriminate by asking questions that are not related to the requirements of the job, or any designed to the test certain candidates more vigorously due to protected characteristics e.g. questions directed to domestic commitments.
Any tests should be conducted in a way that is accessible to candidates and information should be provided in their preferred format. BSL interpreters or other communication support should be provided if required.
Making the selection decision
Once all interviews and tests have been completed and scored, the selection panel are in a position to make a decision. All candidates should be assessed against the job description and person specification for the post applied for.
The Chair of the panel should make every effort to obtain a unanimous decision. Where this is not possible a majority decision will be sufficient.
Where no candidate fulfils the essential requirements of the post the panel will decide either to appoint a candidate who meets the most essential requirements or re-advertise. In the case of re-advertisement, the trustees will consider why no suitable candidate applied and try to address the problem. For example, review pay scale, advertise more widely.
Making an offer
It is the responsibility of the Chair of the panel to contact the successful applicant by telephone and offer them the post. This will be followed up by a letter of appointment subject to references and any DBS check if relevant.
The Chair of the interview panel (or other nominated person) will inform the other unsuccessful applicants and should be able to give feedback if require.
The Chair of the panel will ensure that references are sought, and any checks are carried out if necessary. They will also agree a start date.
Appointment
The BDEF Director will ensure a contract of employment is issued as soon as possible after satisfactory references and DBS and other checks have been received.
The contract will include details of hours of work, pay, leave entitlement and details of other main terms and conditions.
The Director will ensure that any Reasonable Adjustments under the Equality Act are made to the workplace and working practices for Disabled staff.
The recruitment process is completed when the candidate has started in their post and has completed any probationary period that may have been agreed from the outset.
Training
Introduction to the Equal Opportunities Policy and practice will take place during induction and will be continued at appraisals.
Training, where necessary, will be arranged for those who have to make employment decisions e.g. on Fair Recruitment, EDI in short listing, interviewing, appraisals, and employment legislation.
Where appropriate and permissible under the Equality Act 2010, employees with protective characteristics should be given specialist training and encouragement to achieve equal opportunity and progress within the organisation.
Training and other professional development should be provided in a way that takes into account staff members’ individual needs e.g. childcare, religious observance.
Working conditions
BDEF will regularly review its contract and terms and conditions to ensure they do not discriminate against anyone on equality grounds and are in line with best practice on EDI.
Flexibility in working hours will be considered on equality grounds where appropriate and in line with the requirements of effective service delivery.
Consideration will be given to employees’ impairments and access needs, religious observance, childcare and caring responsibilities in terms of agreeing working hours, holidays etc.
BDEF will develop a separate Disability Leave Policy.
Care will be taken to ensure the workplace feels safe and inclusive for all staff, and any concerns raised about discrimination, bullying, harassment or victimisation should be reported to the Director and acted on immediately.
BDEF will not tolerate the harassment of its staff by members or people who use services, and the Director will take immediate action where this occurs, and if necessary find alternative ways to meet someone’s needs outside BDEF. Membership can be withdrawn if necessary. Any staff member who has been harassed or treated disrespectfully will be offered a range of appropriate support.
Service delivery
Staff, volunteers and trustees involved in BDEF should not discriminate against people using services or members by asking questions related to their personal circumstances which do not relate to the issue they are raising.
Everyone approaching BDEF will receive the same standard of courteous and non-discriminatory service.
BDEF will aim to provide a welcoming and accessible environment for everyone. We will do all we can to provide good access for disabled people in terms of reducing barriers in the physical environment and providing information in formats that people require (e.g. providing sign language interpreters if needed).
BDEF will aim to ensure that our services are culturally sensitive, and that our premises are safe spaces that also allow people to meet their religious needs.
We will also provide support in different languages, use interpreters and provide translated materials where required.
BDEF will aim to make its communications (website, newsletters, minutes, leaflets etc) as accessible as possible, avoiding jargon and translating into community languages where required.
We will aim to hold meetings at times that are suitable for people to attend (e.g. avoiding school runs, prayer times etc.) Services will be offered at times that work for members where possible.
BDEF will offer a range of ways for people to find out about, and access, services (phone, social media, leaflets, website, in person).
We recognise that digital exclusion is an issue in the community, and will support people to access services or complete forms through the internet or emails etc.
BDEF will take very seriously any complaints of bullying, harassment or victimisation, and will investigate them, and aim to resolve to the satisfaction of the complainant immediately. (See Complaints Procedure). We will also support people who use our services and members to tackle any such incidents that occur in other settings, particularly where this might be a hate crime, in partnership with specialist agencies.
BDEF will aim to eliminate all discrimination in service delivery and will provide accessible ways for people to report any concerns.
BDEF will seek feedback from members and people who use our services on the accessibility of services and will make changes based on their feedback.
Data collection
BDEF’s data collection and record keeping complies with the requirements data protection legislation.
Any data, either qualitative and or quantitative, required in order to monitor the EDI will be collected where it is reasonable, proportionate and practical to do so.
Any data collection will be explained to BDEF members and people using services and will follow common data format. This policy will be reviewed on an ongoing basis and amended in line with new developments in Equality and Diversity best practice.
Data on equality and diversity in terms of our workforce, trustees and people who use our services will be monitored at least annually by the trustees.
Accessibility
BDEF will ensure that it acts in such a way that everything it does is as accessible and inclusive as possible by:
- Meeting travel costs of trustees, volunteers and those attending meetings where possible;
- Providing information in the format requested and ensuring all BDEF communications meet accessibility guidelines;
- Using the most accessible venues available;
- Making Reasonable Adjustments for staff and volunteers;
- Advising other organisations on accessibility;
- Identifying and challenging other access barriers Disabled people face.
Dealing with third parties
BDEF will not unlawfully discriminate in dealings with third parties. This applies to dealing with other legal service providers and general procurement.
Training
BDEF will ensure that all new employees, volunteers, and trustees receive induction on the policy. Thereafter, BDEF will provide EDI training for all staff, volunteers and trustees whenever legislation and/or good practice changes and in accordance with their role.
EDI will be discussed in supervision and appraisal meetings, and any further staff training needs on EDI will be identified and met.
BDEF will also, within it limited resources and operational needs, ensure additional training opportunities are offered where they would support the individual’s personal development.
Complaints and sanctions
BDEF will treat seriously any complaints of discrimination on any of the stated grounds made by employees, volunteers, trustees, members, people who use services or other third parties and will take action where appropriate.
All complaints made by external parties will be investigated in accordance with the BDEF’s Complaints Procedure. the complainant will be informed of the outcome.
In the event of an investigation concerning a complaint against an employee, BDEF’s Disciplinary Policy and Procedures will be followed and any action necessary will be dealt with.
If any employee feels BDEF as an organisation, the Director, or any staff member or trustee is acting in breach of this policy, they should raise it under BDEF’s Grievance Policy.
Complaints will be monitored annually, and any outcomes/action recorded.
Relevant legislation and policies
This Policy complements, and should be considered along with other BDEF Policies:
- Recruitment Policy
- Volunteer Policy
- Trustee Recruitment Policy
- Complaints Procedure
- Grievance Policy
- Disciplinary Policy
This Policy is informed by the following legislation:
- Equalities Act 2010
- Human Rights Act 1998
- Rehabilitation of Offenders Act 1974
- Employment Rights Act 1996
- Part Time Workers (Prevention of Less Favourable Treatment) Regulations 2000
- Fixed Term Employees (Prevention of Less Favourable Treatment) Regulations 2002
- Civil Partnership Act 2004
- Work and Families Act 2006
- Any other relevant legislation in force from time to time relating to discrimination in employment and the provision of goods, facilities or services
Monitoring and review
The success of any policy depends on the degree of commitment by all trustees, staff and volunteers. The effects of the policy can only be judged from feedback on how the policy operates.
BDEF will maintain a monitoring system to collect relevant data and allow assessment to be made on the progress of developing a fully effective EDI Policy.
All staff will ensure records are kept of applicants, employees, members and people using services’ equality data, but only for the purpose of providing the trustees and funders with information relevant to EDI and within GDPR guidance.
Other policies and procedures will be kept under review, to ensure that they are not contrary to this EDI Policy.
This Policy will be reviewed at least every three years by the Board of Trustees.