Corporate equality, diversity and inclusion policy

1. Purpose
2. Principles
3. Scope and responsibilities
4. Our legal responsibilities
5. Public Sector Equality Duty
6. Making a complaint
7. Consultation
8. Appendix One: types of discrimination

1. Purpose

1.1 Wyre Forest District Council recognises and celebrates the diverse nature of the people who live, work in and visit the Wyre Forest District and are committed to promoting equality, diversity and inclusion and tackling discrimination.

1.2 The purpose of the Equality, Diversity and Inclusion Policy is to set out our commitment to an inclusive and supportive environment that treats people fairly, values differences and removes barriers preventing people from accessing Council services.

1.3 The policy promotes positive attitudes towards inclusivity and valuing diversity. Fostering an inclusive culture helps each of us to benefit from a wider range different perspectives, experiences and skills. We believe that this creates a happier, more productive environment for us all. We are committed to promoting an environment based on dignity, trust and respect, and one that is free from discrimination, harassment, bullying or victimisation (appendix 1).

1.4 This policy seeks to ensure that all who are subject to our policies, practices and procedures are treated fairly and are not treated less favourably on the grounds of any of the protected characteristics as defined by the Equality Act 2010:

• Age
• Disability
• Gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race
• Religion and belief
• Sex
• Sexual orientation

1.5 The policy complies with The Worker Protection (Amendment of Equality Act 2010) Act 2023 and we will take reasonable steps to prevent sexual harassment of its employees in the course of their employment. ‘Harassment’covers unwanted conduct related to a protected characteristic which has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Sexual harassment is unwanted conduct of a sexual nature that has that effect.

1.6 The Equality, Diversity and Inclusion Policy sets out how we seek to meet both our statutory equality responsibilities and aspirations for an inspirational and inclusive environment.

2. Principles

2.1 The Council:

• is guided by its core value that people will be treated fairly and according to their needs.
• supports and promotes equality of opportunity in employment and service delivery.
• will endeavour to treat all people equally and fairly.
• are inclusive and embrace peoples’ differences.
• seeks to eradicate all forms of unlawful or unfair discrimination on the grounds of the protected characteristics.
• accepts that it has a unique and influential position in the community as a major employer and quality service provider.
• acknowledges its legal duties under the Equality Act 2010.

2.2 We will monitor and review all service delivery plans, policies, practices and procedures and address any areas of inequality in accordance with latest legislation and best practice.

Monitoring activity includes:

• identifying possible inequalities associated with relevant policies or functions.
• investigating the underlying causes of these inequalities.
• taking action to remove any unfairness or disadvantage.

3. Scope and responsibilities

Everyone is responsible for and expected to uphold and demonstrate a commitment to the Council Values; We are Working together, We are Fair, We are Dependable, We put Communities first.

The Corporate Leadership Team is responsible for:

• ensuring the Council meets its legal obligations and that everyone should be treated fairly in particular in relation to protected characteristics within the Equality Act 2010.
• zero tolerance for sexual harassment and embedding a culture promoting dignity and respect.
• ensuring that an Equality Impact Assessment (EqIA) is carried out on all proposed policies and decisions where appropriate.

The portfolio holder and elected members are responsible for:

• being familiar with the Council’s Equality, Diversity and Inclusion policies and understanding the extent to which it has an impact on their role
• observing and promoting the policy in the performance of their roles and duties
• ensuring adequate resources are available for the Council to meet its legal responsibilities concerning equality of opportunity
• contributing to the scrutiny of equality work as required and driving forward change through the relevant Committees, panels or working group

HR are responsible for:

• leading the process of embedding equality, diversity, and inclusion principles across the authority
• setting appropriate standards, communicating best practice, providing relevant training and support and challenging current practice
• evaluating progress against relevant action plans

Responsibilities regarding employment

We will have consideration for the following:

• be a fair and equal opportunity employer in all areas of employment, including recruitment and selection, and career development, ensuring that individuals are selected and promoted according to their relevant merits and abilities
• ensure that all employees and elected members are involved with recruitment are appropriately trained to avoid unlawful discrimination.
• ensure that job applicants do not receive less favourable treatment, unless there is a genuine occupational requirement for a restriction being placed on a particular post (this would only be applied when all other employment options had been excluded).
• draw job applicants from the wider labour market to ensure that a diverse range of job seekers is made aware of the opportunities with the Council. This will be achieved by communicating job opportunities to all sections of the community without discriminating or discouraging applications from any particular section.
• make this policy available to job applicants and existing employees, elected members and relevant organisation
• take positive action wherever practicable to retain and redeploy existing employees who become disabled or who, on account of changes in personal circumstances, are unable to continue in their existing job
• take all complaints from employees regarding discrimination, victimisation or harassment seriously by ensuring such incidents are investigated thoroughly and promptly. Under our disciplinary procedure breaches of this policy, including serious acts of harassment, victimisation, discrimination or verbal abuse against employees, clients or members of the public on grounds any protected characteristics may be regarded as gross misconduct and may lead to termination of employment.
• ensure all employees are treated fairly and equally in terms of conditions of employment and contractual rights.
• seek advice from external support programmes in relation to opportunities and services available for people with disabilities.
• ensure its commitment to equality in all aspects of employment, recruitment selection, career development, training and promotion is maintained, and that procedures, practices and records are monitored and evaluated accordingly.
• ensure as far as possible that the composition of our workforce reflects that of the local community and to take any steps permitted by law to help disadvantaged and under-represented groups to compete for jobs on a genuine basis of equality.
• ensure that all job applicants and employees receive the help they need to attain their full potential to the benefit of the Council and themselves.
• continually monitor and seek the views of employees through the creation of an EDI taskforce.
• undertake and maintain monitoring and regular analysis of internal records providing a basis for appropriate action to eliminate unlawful discrimination, harassment, or victimisation.
• ensure that all employees receive equality and diversity training.
• establish strong links with Trade Unions, managers, and employees in order to consult regularly and effectively when employment policy is developed and review.

Responsibilities regarding service provision

We will:

• ensure our approach to customer service, quality and equality is relevant to all services and involves all employees who will be appropriately trained to avoid discrimination and stereotyping.
• equip employees with the skills, knowledge, and competencies to provide services in a flexible and sensitive manner encouraging good communication between employees and customer
• increase understanding of the different needs of all people in the community through the use of more effective consultation.
• seek to serve all our customers and potential customers equally, fairly and with respect and ensure that its policies and procedures do not discriminate against any individual or group of people.
• seek to avoid discrimination when designing, delivering, or charging for service
• ensure that, wherever practicable, all public buildings and premises owned or occupied by us have access and other facilities for people with disabilities.
• seek to respond to any special need requirements of any particular group
• work to remove all cultural and linguistic barriers that may confront our customers whose first language is not English
• ensure that the procurement of goods and services:
• is undertaken by contractors, suppliers, and partners without unlawful discrimination in line with our procurement standards.
• includes all relevant standards and recognised national guidelines
• positively addresses all equality issues during the tendering and selection procedures.
• is monitored regularly to ensure that its equalities standards are being met.

As part of our commitment to maintaining and improving our performance we will, where practicable:

• develop sensitive and appropriate equal opportunity monitoring systems where relevant to identify service take-up by age, ethnicity, disability, and gender.
• develop realistic qualitative and quantitative performance indicators and outcomes which are specific, measurable, and time-tabled for service delivery.
• monitor the customer complaints procedure to identify complaints that relate to equality, diversity or inclusion and act accordingly as a result of the investigation.

Responsibilities regarding working with partners and contractors

In all aspects of partnership working we will encourage partners, from whatever sector, to work with us to support the principles of this equality and diversity policy.  As a major purchaser of goods and services we will operate fair contracting and procurement policies that monitor compliance with equality requirements and will encourage and support contractors to develop best practice in equality.

Responsibilities regarding equality target groups

We will continue to develop relationships with existing potentially disadvantaged groups which are diverse and dispersed throughout the district. We are committed to working in partnership with and developing relationships with hard-to-reach groups and organisations representing potentially disadvantaged groups.

In particular we are committed to identifying groups within the community whose needs are less well met by our services than those of other groups. Having identified such needs we will work with those groups to consider the steps we could take to address them.

Responsibilities regarding equal access to information and services

We are keen to ensure that everyone has access to the information they need at the time that they need it and improving communication is central to this.

• Information is available through our Customer Service Centre in Kidderminster, by telephone and from our website.
• Translation services are available on request.
• Documents can be converted to larger print on request.
• Induction loop facilities are available at several buildings used by the public.

4. Our legal responsibilities

The Policy is in accordance with relevant equalities related legislation, in particular the Equality Act 2010 and The Worker Protection (Amendment of Equality Act 2010) Act 2023.

5. Public Sector Equality Duty (PSED)

The Public Sector Equality Duty (PSED) ensures organisations consider how their functions will affect people with different protected characteristics including policies, programmes and services.  The duty supports good decision making by helping decision makers understand how their activities affect different people and requires public bodies to monitor the impact of the things they do.

5.1 General duty

Under the Act, the general duty requires us to have due regard to the need to:

• Eliminate unlawful discrimination, harassment, victimisation and any other unlawful conduct prohibited by the act.
• Advance equality of opportunity between people who share and people who do not share a relevant protected characteristic.
• Foster good relations between people who share and people who do not share a relevant protected characteristic.

5.2 Specific duties

The specific duties are intended to enable more effective performance of the general duty and standardise some work of general duty holders. The specific duties complement the general duty but do not replace it.  Our specific duties, which are published on our website, are to:

• Publish one of more equality objectives at least every 4 years.
• Publish information on general duty compliance regarding people affected by our policies and practices every year.
• Publish information on general duty compliance regarding our employees every year.
• Publish gender pay gap data by 31 March every year.

5.3 Our objectives

We will provide services and facilities that are fair and accessible to meet the diverse needs of our communities.

We will achieve this by:

• carrying out equality impact assessments to ensure decision making is fair and that no group is disadvantaged.
• analysing customer data, via information obtained from our Let Us Know process, to enable us to improve service delivery.
• providing a range of channels for residents and businesses to easily access information about council services.
• ensure that all digitally published materials are accessible to people with disabilities and ensuring the council's website meets web accessibility standards.

Provide organisational commitment to actively promote inclusion through better understanding of our workforce/potential workforce and be seen as an employer of choice.

We will achieve this by:

• analysing and responding to any issues or disparities found through our collection and recording of recruitment diversity data (based on the protected characteristics as identified in the Equality Act 2010), as well as through our gender and ethnicity pay gap reporting.
• providing Equality, Diversity and Inclusion (EDI) training to all our staff and elected members.
• creating a staff Equality, Diversity and Inclusion task force to influence and challenge EDI work and activities at the council.
• review and consider findings of employee engagement surveys to make informed decisions around equality and inclusion within the organisation.
• publish workplace profile and gender pay gap reports annually on our website.
• proactively promote recognised dates that celebrate diversity and support inclusion across the workforce.

6. Making a complaint

6.1 We take complaints about the services we provide or about the people we employ seriously and have a well-established corporate complaints procedure for dealing with any type of complaint from members of the public or outside bodies. This procedure is fully accessible to all members of the community.

6.2 All complaints will be properly and fully investigated within an agreed timescale and people who have raised complaints, whether members of the public or employees, will be informed of any conclusions reached.

7. Consultation

7.1 We aim to build on our established methods of consultation and remove barriers to participation by providing information to the community in the following ways:

• Customer satisfaction surveys
• Social media
• Working parties and focus groups
• WyredIn
• Press releases and public notices

7.2 We will work to improve our ability to target and consult with under-represented groups in the community.

7.3 Any breach of this policy will be taken seriously and dealt with under the appropriate policies.

Appendix One: types of discrimination

There are various types of discrimination prohibited by this policy. The main types are:

1. Direct discrimination

Direct discrimination occurs where one person is treated less favourably than another because of a protected characteristic set out in this policy. By way of example, a landlord refuses to rent their property to you based on your sexuality would be direct discrimination on the protected characteristic of sex. Other types of direct discrimination are:

Associative discrimination

This is direct discrimination against someone because they associate with another person who possesses a protected characteristic. 

Perceptive discrimination

This is direct discrimination against an individual because others think they possess a particular protected characteristic. For example if an organisation thinks you have a disability when you don’t.

2. Indirect discrimination

Indirect discrimination occurs when an unjustifiable requirement or condition is applied, which appears to be the same for all, but which has a disproportionate, adverse effect on one group of people. This is discrimination even though there was no intention to discriminate. For example, where a local authority applies a policy to everyone, but the policy puts a disabled person at a particular disadvantage compared to others with no disabilities.

3. Victimisation

Victimisation is where someone is treated less favourably than others because they have asserted legal rights against the organisation or assisted someone else in doing so.

4. Harassment

Harassment is “unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.”

Sexual harassment is unwanted conduct of a sexual nature that has that effect. Examples include, sexually offensive jokes, displaying/sharing pornographic or sexual images and touching someone against their will, for example hugging them.

It is important to remember that it is not the intention of the harasser but how the recipient perceives their behaviour, which determines whether harassment has occurred.