Document Title  Equality and Diversity Policy
  Version  1.7
  Status  Final
  Issued  May 2013
  Reviewed  January 2021
  Author  SMT
  Reviewed by    Richard Jenkins CEO
  Next Review date  January 2022  

The policy has undergone an Equality Impact Assessment (EQIA) confirming that there are no negative consequences in the case of this policy

Previous VersionDateActionAmendments
1.6Jan 2021ReplaceSafe Additional Needs Support Team with Training Team Co-coordinator Some may have had very negative experiences of the level of support they’ve had in the past and will need to be encouraged to tell us their needs. Once you have been told such information you must refer it to the Training Team Co-coordinator Safe Additional Needs Support Team or the equivalent team or person in your organisation so that appropriate support can be put in place.
  ReplaceAdditional Needs Support Team with Safeguarding Team   Some learners or trainees will come to ETS with an EHCP (Education, Health & Care Plan). This is a legal document and we must take account of what is written if we have already interviewed and agreed to enrol the learner. By doing so we are agreeing that we can provide the support required. This document must be held by the Safeguarding Team and the actions advised by them to our training facilitators’ tutors/ assessors must be followed. Some learners or trainees with specific needs may not come to ETS with their needs already assessed and those learners need to have an opportunity to tell us what their needs are and how best we can support them. Some may have had very negative experiences of the level of support they’ve had in the past and will need to be encouraged to tell us their needs. Once told such information it must be referred to the Safeguarding Team so that appropriate support can be put in place.


Introduction

Education + Training Skills (ETS) is committed to the principle of equal opportunities and diversity; both in its employment practices and in the learning activities it delivers. As a government funded organisation ETS recognises that it needs to set an example for others in the field and for the business organisations that it works with. ETS recognises that it must ensure that it is able to recruit, develop and retain a workforce that is able to deliver high standards of work and who are representative of both local and national populations. It must ensure that it is free from both direct and indirect discrimination in its employment policies, procedures and practices. It also needs to ensure that the organisations that it works with also work to these standards. ETS strives to go beyond compliance and to be at the forefront of embracing equality and diversity. ETS intends to promote good practice and to be sensitive to the specific needs of both its employees, learners, partners, stakeholders and their communities.

ETS promote this policy by not tolerating discrimination against any employee, job applicant or learner on the grounds of age, race, sex, religion and beliefs, gender or gender reassignment, sexual orientation, disability (including HIV status), marital or civil partnership status, pregnancy or maternity, membership or non-membership of a Trade Union, Trade Union Activity, responsibility for dependents, political beliefs or part-time working. ETS will ensure and promote quality of opportunity for all staff regardless of their role within the organisation, all learners regardless of their role with in the business/organisation they are working in, and to inform staff and learners of their rights and responsibilities and opportunities that are available to them to progress and grow.

ETS recognises that the workplace consists of a diverse population and that for the organisation to be truly inclusive, differences of culture, background, preferences and values are recognised, understood and valued allowing all talents to be harnessed rather than suppressed. ETS recognises people’s differences and the benefits these bring to business efficiency and prosperity and promotes and encourages people to use their differences creatively.

Scope

This policy applies to all employees who work under a Contract of Employment with; and all consultants who work under Contracts of Services to ETS.

This policy cannot be applied directly to third parties. However ETS staff must make any third party, for whom they are responsible, aware of ETS’s policy on equal opportunities and diversity. If a third party should be found to have breached the principles of this policy their agreement and working relationship with ETS will be terminated.

Policy Statement

Any behaviour or actions against the spirit and/or letter of the laws on which this policy, and its associated policies, is based will be considered as a serious disciplinary matter that could lead to dismissal.

Principles

This policy covers all aspects of employment and learner recruitment from vacancy advertising, recruitment and selection, conditions of employment, training and development, promotion and appraisal through to termination of employment. It is supported by, and should be read in conjunction with other ETS policies and procedures, such as:

  • Recruitment and selection
  • Dignity at work (harassment and bullying)
  • Public Interest Disclosure (Whistle blowing)
  • Disciplinary and Grievance.

Aims and beliefs

ETS’s aim is to prevent and eliminate any form of discrimination on the grounds of age, race, sex, religion and beliefs, gender or gender reassignment, sexual orientation, disability (including HIV status), marital or civil partnership status, pregnancy or maternity, membership or non-membership of a Trade Union, Trade Union Activity, responsibility for dependents, political beliefs or part-time working.

ETS believes that it is in the best interests of all to ensure that a full range of skills and experience available within the education, training and skills sectors are considered when employment opportunities arise.

Investing in and promoting equality and diversity and engaging with staff and customers through training, the website via newsletters and other communications will assist ETS to improve staff and learner retention rates, improve morale and improve services.

Duties and responsibilities (for equal opportunities, diversity and inclusion)

Employer’s responsibility

ETS’s responsibility as an employer is not just to comply with the letter and spirit of the law on equal opportunities (see Appendix 1) but to demonstrate that it is a fully inclusive employer.

ETS has a statutory duty to implement and monitor equality schemes in respect of all protected characteristics.

To embrace good practice in all of ETS policies and procedures and to act to eliminate discriminatory practice whether direct or indirect.

To value diversity in society and in its workforce enabling all employees to reach their full potential.

To monitor the application of the equal opportunities and diversity policy and work towards eliminating any discrimination, either direct or indirect, which may be limiting the organisation’s ability to achieve its vision.

To be a fair and responsible employer, and to set an example to other businesses/organisations, learners and stakeholders that it works with.

To provide as a minimum annual training in equality and diversity to its staff during its annual CPD training week and its new induction training.

Employees’ responsibility

  • Attend/undertake the annual and in year training offered in equal opportunities so as to implement the spirit of the policy
  • All members of ETS’s staff must recognise their responsibilities to adhere to and comply with the letter and spirit of this policy.
  • To ensure that there is no discrimination in any of their decisions or behaviours.
  • To inform managers/co-ordinators if they suspect that discrimination is taking place or that the policy is not being adhered to.
  • To co-operate with management in the application of any measures introduced to ensure equal opportunity and diversity.
  • To co-operate with senior management in the elimination of any discriminatory practices which may be identified
  • To engage with and inform learners, employers and other stakeholders of our expectations of them on the matter of equality and diversity and how they can implement our values within this policy in their own organisation and personal lives.

Manager’s/Co-ordinator’s Responsibility

Managers are responsible for the practical application of the policy and in particular to ensure that:

  • They engage with all staff, businesses/organisations, learners and other stakeholders, under their control, and make them aware of the policy and their responsibilities to adhere to and comply with the letter and spirit of this policy;
  • There is no discrimination in any of their decisions or behaviour
  • Proper records of employment decisions are maintained
  • Fair standards of employment practice are maintained
  • To actively engage in any measures that are introduced to ensure equal opportunity, diversity and inclusion
  • Attend all training offered in equal opportunities
  • Promote and comply with our disability confident status

It is unlawful for any Manager/Co-ordinator, or anyone else in authority to instruct or induce others by pressure to discriminate.

Senior Management

Senior Management will be responsible for:

  • Advising on and developing an equal opportunities and diversity policy which mirrors good practice
  • Providing a detailed review of progress on the policy and action plan
  • Providing equal opportunities and diversity training across ETS to ensure that all staff and management are aware of their responsibilities
  • Collating and reporting on equal opportunities data covering recruitment of staff and learners, staff in post, promotion, training opportunities, grievance and disciplinary procedures, resignations, dismissals, (including redundancies) and incidents of harassment
  • Senior managers will be responsible for the review and updating of this policy on an annual basis as a minimum.
  • Overseeing the promotion of the policy through all means necessary eg. Interviews, Appraisals, 1 to 1’s website, posters, newsletters

ETS’s vision

ETS will work towards achieving the following with its equal opportunities, diversity and inclusion policy:

  • A workforce that is representative of the local and national community
  • A balance of staff at all grades in terms of gender, ethnicity and disability
  • All staff being encouraged to reach their full potential regardless of gender, ethnicity or disability
  • Working with staff, partners and employers to promote equal opportunities and promote good employee relations
  • Implementation of a flexible working policy to provide a range of working patterns for all employees to enable them to achieve a work life balance appropriate to their individual circumstances and responsibilities and which will enable the policy to be uniformly applied
  • Elimination of any conditions, procedures and individual behaviours that could lead to discrimination even where there is no intent to discriminate, with particular regard to:
    • Age, race, sex, religion and beliefs, gender or gender reassignment, sexual orientation, disability (including HIV status), marital or civil partnership status, pregnancy or maternity, membership or non-membership of a Trade Union, Trade Union Activity, responsibility for dependents, political beliefs or part-time working.

Monitoring and evaluation

Monitoring is an essential part of ETS’s equal opportunities and diversity policy. In order to ensure that the policy is effective and to enable action to be taken to prevent and eliminate any unlawful direct or indirect discrimination (and for no other reason), equal opportunities data will be collected, maintained and monitored in respect of age, gender, disability and ethnicity in relation to recruitment of staff and learners (including short listing and selection decisions), promotions, training, resignations, redundancies, grievance and disciplinary cases and complaints of harassment. This data will be kept for both employees and learners making application to ETS.

This data will be evaluated on a quarterly basis and reported, with relevant recommendations to the Senior Management.

The data from monitoring will be reviewed to assess the effectiveness of the policy. Where factual evidence shows the policy to be ineffective, the policy will be reviewed to ensure that equal opportunities are afforded to all applicants both staff and learners.

Action Plan

ETS’s action plan has been designed to assist the organisation to meet the vision for equal opportunities and diversity. The action plan will be kept under review on an annual basis.

ETS’s action plan is to:

In general

Comply with all legislation dealing with discrimination and promotion of equality, following codes of practice to support this legislation.

Ensure that all employment policies, procedures, guidelines, marketing materials and other publications reflect and reinforce ETS’s commitment to equal opportunity and diversity.

Recruitment and selection policy will include mandatory competency selection skills training; selection criteria will be constantly reviewed to ensure that it is justifiable on non-discriminatory grounds. In all cases more than one person will carry out short listing and interviewing, ETS will adopt a consistent, non-discriminatory approach to the advertising of vacancies. Promotion and advancement will be made on merit and all decisions relating to this will be made within the principles of this policy.

Specifically

ActionTimelineStatus
Review the way in which we collate and monitor equal opportunities and diversity dataAnnuallyOngoing
Provide management information relating to equal opportunities and diversity to CEO and Governors quarterlyOngoingOngoing
Review the embedded teaching and learning directed at learners both in the classroom and in the workplace and challenge learners to ensure learning has taken place and been effectiveOngoingOngoing
Review the results of equal opportunities monitoring and take positive action where necessary and appropriate to address any under representation or any area which might disadvantage any particular group of peopleOngoingOngoing
Aim to increase the balance of ethnicity within the recruitment of staff and  learners to reflect local populationsOngoingOngoing  
Employ staff with a disability Min 10%OngoingOngoing
Maintain a flexible working scheme which will provide a range of working patterns for all employees to enable them to achieve a work life balance appropriate to their individual circumstances and responsibilities and which will enable the policy to be uniformly applied  OngoingOngoing
Ensure that all managers/co-ordinators and staff are trained, conform to and are fully cognisant of all equal opportunities legislation and issues and have access to advice and guidance at all timesOngoingOngoing
Continue to review accessibility to the centre to ensure that all facilities are fully accessible: Provide appropriate assistive technologies and make Appropriate adjustments, eg alternative lighting, equipmentEnsure that all public areas, meeting rooms and staff areas have adequate lightingAnnually    Accessibility risk assessment carried out annually.
Review all publications to ensure that all sections of the population are representedAnnuallyOngoing
Monitor specific impact of Covid-19 on legislation, employment policies, procedures, guidelines, marketing materials and other publications and ensure they comply with ETS’s commitment to equal opportunity and diversity.OngoingOngoing

Evaluation of the policy and action plan

The policy and action plan will be evaluated on an annual basis. This review will involve consideration of progress made and priorities for future action plans.

Responding to feedback or complaints

ETS is committed to responding quickly and constructively in relation to all complaints including any that are in relation to equal opportunities.

ETS recognises that making complaints or expressing a concern regarding equality of opportunity or discrimination can be intimidating or uncomfortable. ETS is committed to ensuring that any individual should feel able to come forward with a complaint and provides a range of procedures and support mechanisms to support individuals who have a concern.

ETS will take appropriate action to protect staff and learners from discriminatory behaviour by any individual or groups. Allegations of discriminatory behaviour will be dealt with under the appropriate procedure:

  • Grievance Procedure
  • Disciplinary Procedure
  • Anti-Harassment and Bullying Policy
  • Whistle Blowing Policy.

Addendum

  • The policy also applies to Skills Support for the Workforce/ Redundancy contract for the Heart of South West – Transitional LEP Area (ESF-5112)
  • The policy also applies to Skills Support for the Workforce/ Redundancy contract for the Dorset – More Developed LEP Area (ESF-5127)


Appendix 1

Legislation affecting equal opportunities and diversity.

ETS Equal opportunities and diversity policy takes account of the relevant Acts of Parliament. These include:

  • Equality Act 2010

Other relevant legislation includes:

  • Human Rights Act 1998
  • Flexible Working (Procedural Requirements) Regulations 2002
  • Part time workers (Prevention of less favourable treatment) Regulations 2000 and 2002
  • The Fixed Term Employees (Prevention of less favourable treatment) Regulations 2002
  • Maternity and Parental leave regulations 1999, 2001 and 2002
  • Paternity and Adoption leave regulations 2002.

ETS Equality and Diversity Internal Quality Cycle

What elements of our evidence persuade us that our practice in relation to EDI is good as well as meeting the requirements of the Equality Act 2010?

Where we feel there are shortcomings, what steps could we take to develop and improve?

  • When was the last time ETS undertook an equality and diversity audit of our teaching and learning processes? How recent was it?
  • What were our findings or outcomes and, importantly, how did we act upon them?
  • How did we involve our learners in our audit?
  • Who else did ETS consult e.g. colleagues, internal advisors or external organisations?
  • What process did ETS follow?
  • How do we ensure equality, diversity and inclusion forms part of your teaching observation process?

Understanding Individual Needs

Avoid Stereotyping

ETS should avoid at all costs to fall into the trap of stereotyping and pre-judging people based on labels.

ETS must be clear about the difference between what we know about the learner or trainee and what we infer from the evidence we see. ETS need to be sure of the facts through the process of initial assessment. Beware of your own unconscious bias.

Cultural Background

Most of our learners or trainees will have been through the primary and secondary education system in the UK so will be well aware of different teaching and learning styles and methods and the benefits of the interactive classroom or workshop. Some learners or trainees may come from a culture where the focus is on didactic, teacher-centred learning. These learners and trainees may find ‘active learning’ methods more difficult to work with as they are unfamiliar with them.

Some learners and trainees come from a culture where education is valued much more highly. These students may well put themselves under much more pressure than other students and may respond negatively to even quite small criticism. Female learners or trainees may find discussion groups with male peers more difficult if they are from a culture where women’s views are valued less than those of their male counterparts or where working with male learners they don’t know poses a problem.

Education Experience

Some learners or trainees may have had a very negative experience of education. Some may have low self-esteem, others might have unrealistic expectations of what they can achieve. Exploring how they perceive education and identifying key moments of their previous experiences in a learning environment can give you an insight into their attitudes to others as well as their self-perception.

Special/Additional Needs

Some learners or trainees will come to you with an EHCP (Education, Health & Care Plan). This is a legal document and we must take account of what is written if you have already interviewed and agreed to enrol the learner. By doing so ETS is agreeing that it can provide the support required. This document must be held by the Safeguarding Team (Additional Needs Support Team) and the actions advised by them to our tutors/ assessors must be followed.

Some learners or trainees with specific needs may not come to ETS with their needs already assessed and those learners need to have an opportunity to tell us what their needs are and how best we can support them. Some may have had very negative experiences of the level of support they’ve had in the past and will need to be encouraged to tell us their needs. Once you have been told such information you must refer it to the Training Team Co-coordinator so that appropriate support can be put in place.

Additional Support Requirements

Some learners or trainees will come to ETS with an EHCP (Education, Health & Care Plan). This is a legal document and we must take account of what is written if we have already interviewed and agreed to enrol the learner. By doing so we are agreeing that we can provide the support required. This document must be held by the Safeguarding Team and the actions advised by them to our training facilitators tutors/ assessors must be followed.

Some learners or trainees with specific needs may not come to ETS with their needs already assessed and those learners need to have an opportunity to tell us what their needs are and how best we can support them. Some may have had very negative experiences of the level of support they’ve had in the past and will need to be encouraged to tell us their needs. Once told such information it must be referred to the Safeguarding Team so that appropriate support can be put in place.

Aspirations

ETS staff will need to know why the learner or trainee has come to ETS. Do they have a particular goal in view and is this realistic for them? Ensuring learners, trainees or apprentices are on the right programme and giving advice and guidance is important. In some contexts we might be able to guide them on to a different programme if appropriate. In other contexts we may have to discuss their aspirations to make them more realistic and possibly tailor the content of our programme(s) to suit their needs more effectively. Beware own unconscious bias.

Learner Expectations of the Trainer

It’s always helpful to discuss the learner or trainee’s expectation of ETS staff. We may need to emphasise the importance of their role in the learning environment in developing relationships with their peers and taking responsibility for their own learning and training. Some may view it as the job of ETS staff to spoon-feed them what they need to know. So it’s important to go through the course and the variety of learning methods and assessment so the learner/ trainee will know what to expect.

Life Experience

If the learner or trainee is prepared to share information with us about their previous life experiences in the context of how they feel about learning this could give you valuable insight(s) into how to work with them and potential issues around how they engage with their peers.

 Appendix 2

EQUAL OPPORTUNITIES STATEMENT

Education and Training Skills

We are an equal opportunities employer. Our future success in a highly competitive world depends on our employees and the development of their skills and abilities.

It is our aim that there shall be equal opportunities in this organisation. There will be no discrimination on the grounds of gender, marital status, ethnicity, race, disability, sexual orientation, religion, belief and age.

This principle will apply to recruitment, training, promotion, dismissal, transfer and all other benefits and terms and conditions of employment

All employees have a responsibility to apply this principle in practice

                                        
Signed by Chief Executive Officer                                       Date 6 January 2021

Appendix 3

Communication

Aim: Ensure Equality & Diversity is communicated to staff, learners, employers and other stakeholders.

How will this be achieved:

  • Equality & Diversity Plan will underpin all marketing and communications generated.
  • The policy and plan, where appropriate, will be delivered to staff through induction, and annual training and appraisals whilst the policy will be delivered to learners, employers and stakeholders through IAG, Recruitment and programme induction
  • Equality and Diversity will be embedded within ETS daily operational practices

By Whom? ETS Contract Manager, Staff and Participants
When? Ongoing

Participants

Aim: Communicating integral information effectively to participants

How will this be achieved:

  1. A robust induction process will cover the policies for anti-harassment and anti-bullying. This will be reinforced by poster and notices around the learning environment on on our website to promote and re-enforce these policies. In addition, discussions with learners and employers during Individual Learning Plans and progression reviews will remind learners of this information and the importance of EDI. – By ETS Contract Manager, Staff and Participants – Ongoing
  2. Good relations will be promoted throughout ETS with staff acting as role models and encouraging participants to do the same as well as dealing with any poor relations through 1:1 discussions.- By ETS Contract Manager, Staff and Participants – Ongoing
  3. Liaise with all stakeholder organisations regarding any barriers to participation of priority groups. Promote good practice through attending provider and employer events and learner reviews. By ETS Contract Manager, Staff and Participants – Ongoing

Aim: Ensuring that needs of participants are met

How will this be achieved:

  • Ensure Language needs are met through transcription and interpreter organisations, including Language Line for tailoring materials/software, and local translators as appropriate
  • Ensure reasonable adjustments are (when appropriate) made to allow access for participants with disabilities.
  • Include identification of religious/cultural needs in the initial assessment for all participants by asking them to identify any religious affiliations and consequent needs as part of their protected characteristics assessment and develop and record confidential individual plans to meet allow time for religious and cultural needs are met

By Whom? ETS Contract Manager, Staff and Participants
When? Ongoing and recorded for quarterly contract meetings

Maximising Accessibility

Aim: Ensure appropriate level of inclusivity.

How will this be achieved:

  • Representation from various groups will be reviewed regularly. ETS Contract Manager – Quarterly
  • These monitored groups will be as stated below with the following tolerances:
Participants from ethnic minorities10%
Female participants46%
Participants without basic skills18%
Participants with a disability10%
Participants who live in a single household with dependent children6%

Underperformance of specific groups will be discussed within a quarterly review with actions to try and resolve areas of underrepresentation (if appropriate).

By Whom? ETS Contract Manager
When? Quarter reviews, Provider events

Integrating Equality and Diversity

Aim: Ensure staff have support and reasonable adjustments are made where necessary.

How will this be achieved:

  • Communications will be maintained with staff to identify any further support that may be required. Staff will be familiar with processes to raise any personal concerns.
  • Staff equality objectives can be raised through Annual Appraisal, 1:1 meetings, Team Meetings, Coordinator Meetings, Management Meetings and Standardisation Meetings.

By Whom? ETS Contract Manager
When? Annually, Monthly, Ongoing

Aim: Ensure staff receive Equality and Diversity training.

How will this be achieved:

  • All ETS Staff will undertake Equality and Diversity Training during their Induction Training, and as part of their annual refresher training.
  • Staff will receive the latest updates on equality and diversity information.

By Whom? ETS Contract Manager
When? Quarterly reviews, Ongoing

Aim: Ongoing development and research of Equality & Diversity

How will this be achieved:

  • Review staff and learners by characteristics on an annual basis measuring:  sex, race, disability, age identifying any underrepresented groups.
  • Plan to overcome any underrepresented groups
  • Monitor and review priority groups on a quarterly review and provide feedback of areas of underrepresented groups.

By Whom? ETS Contract Manager
When? Annually