Managing diversity: developing a diversity strategy and policy
Identify and prepare top management in your organisation to adopt a leadership role in driving the strategy Prepare a vision for the organisation relating to diversity Draw up a strategic diversity plan encompassing high level outputs and accountabilities across the organisation Develop an equality and diversity policy outlining commitment, responsibility, scope and content Understand the purpose and component
parts of a robust diversity audit in order to establish the present position
of the organisation |
Introduction
There is a lot of activity which must be undertaken to effect attitudinal, behavioural and systematic change, but this rests firmly in the implementation stage of the diversity programme and is dealt with in some detail in Section 5 . This section is concerned with constructing a proper framework which secures long-term commitment, understanding and awareness.
The following areas are fundamental to the development of the strategy.

Leadership
There is little doubt that the most important component of any strategic change intervention is visible, demonstrable, top-level commitment to that change. This statement is common knowledge to the most progressive diversity practitioners, but still needs re-iterating and reinforcing from time to time. Yes - things will still happen in organisations without this commitment, but they will be piecemeal initiatives lacking co-ordination and will eventually lose momentum, drive and passion.
The correlation between leading-edge organisations in diversity and the effective leadership of them by board members, chief executives and chairmen is very strong. These individuals have sponsored and stewarded enormous activity within their respective organisations and then urged chief executives of other organisation to instil good diversity leadership into their own business strategies. This has jolted their peers and competitors into action and at the same time injected considerable corporate pride into their own organisation, as employees feel their organisation has pushed back the boundaries and has established itself as a market leader in diversity.
How do you get leaders' commitment?
Organisational culture, leadership style and personal attitude, will always play a major role in securing leadership commitment. There is no magic formula but certain trends have emerged in recent years which have been successful in both identifying leaders and getting them to demonstrate commitment and drive the strategy forward.
Checklist for Identifying Leaders
Once leaders have been identified, work needs to be done to a) secure their understanding and buy in and b) discuss activities that they need to undertake to move the strategy forward.
The leaders will require a combination of support and challenge to let them grow and develop into this role. Ideally, over time, the diversity manager should feel confident in exposing the leader to various situations where key messages can be conveyed and reinforced, with conviction, knowledge and passion.
Checklist for Developing the Leader
What activities would a leader undertake?
Obviously this will depend on culture, processes and personalities, but a strong leader would add value by:
The leader's role is fundamental. To have an ambassador of diversity who can engage people, sell the concept, influence dissenters and demonstrate personal commitment is a major step towards integrating diversity into the way an organisation does things. The role models in this area do not come easily. However, once identified and on board, the same role models can become extremely passionate about the whole area of diversity which provides the diversity practitioner with a sound ally and sponsor, as well as a sense of satisfaction and progress.
Vision
What is a vision statement on diversity?
Many organisations now develop a specific statement on diversity to provide direction and purpose for the strategy. Depending on the culture, these visionary statements can range from one sentence to three or four paragraphs.
However, the increase in general corporate vision statements sometimes enables a commitment to diversity to be included in broader corporate values. The focus on social responsibility also embraces diversity conveniently and enables values and vision around diversity to be nicely integrated.
Whatever method is deployed to project the vision there is a need to align the vision with the overall business objectives and for the vision to be a lot broader then merely a statement relating to the dignity and respect of staff.
Organisations should plan an appropriate launch of the vision statement which is communicated from the top of the organisation and reinforced at appropriate opportunities as the Strategy and Policy is communicated.
Whether the vision is articulated through a corporate or stand-alone vision statement, it needs to be reinforced at every available opportunity. As with any change management strategy, drip-fed and repeated communication has a strong chance of being adopted into corporate language and understanding.
Strategy diversity plan
Diversity is a fundamental business issue and requires long-term planning and commitment to effect real personal and organisational change. To facilitate this change a high-level plan needs to be drawn up which outlines:
The plan should be rigid enough to have a reasonable shelf-life which does not need changing every three months, yet is flexible enough to accommodate business, societal and legislative changes. Ideally a strategic plan should have a focus of three to five years to truly embed Diversity into the business.
Who develops the plan?
At this stage of the process it is unlikely that full business buy-in has been secured, particularly from areas outside of the HR and diversity functions. Therefore, meaningful input to the planning process may be restricted to the diversity function. If possible, consultation and liaison with the key stakeholders should take place, particularly the individual selected to act as lead champion in diversity.
There will, by necessity, be some interdependencies with other business units and individuals to develop the plans. To obtain their support to planned activities at this stage will present 'show stoppers' appearing later down the implementation line.
One area of the plan that is non-negotiable however is the 'sign-off' element. The most senior level of sign-off must be secured and preferably on a collective basis across the most senior management teams. There is little hope of a strategic plan being taken seriously across the organisation unless it has the top-level sanction. Hopefully, members of the senior management team will also be accountable within the plan and therefore the consultation and ultimate communication process becomes even more important in effecting sustained change.
Timeline plan
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Analysis of present position |
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Benchmarking |
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Policy analysis and development |
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Year two |
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Policy and process changes |
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Level 2 communications to reinforce and engage |
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Commencement of training programmes to top line |
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Year three |
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Development of functional diversity plans |
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Building diversity into performance management systems |
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Full roll-out of training and education |
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Year four |
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Sustained behavioural change |
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Alignment of diversity and business plan |
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Full measurement indices and data |
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Evaluation,
benchmarks and external profile |
How should a plan be structured?
While not wishing to dilute the importance of the plan itself, it is not the way a plan looks or feels which is the ultimate test - it is whether there has been any measured progress towards achieving the goals themselves. As a result, the structure of a plan needs to be one that appeals to the culture of the organisation and the people that will be touched by it.
Example plans are outlined later, but they can be structured in different ways to suit individual organisations. Generally speaking, strategic diversity plans will be built around one of the following three models:
Plans based on timelines can be effective at plotting a future vision and in managing expectations. Too many organisations expect to see lots of activity with measurable results within the first year. However, as organisational behaviour and workforce metrics may not improve until well down the timeline, people held accountable may be under pressure to accelerate progress. The plan needs to be sold at the outset as being 'under the waterline' in the early years but a diagnostic and analytical approach that will reap rewards later.
The population plan, which is based around the groupings of employees and customers under race, gender, disability, and so on, has its roots in the days of 'equal opportunities', when activity related to legislation and compliance. Its position is less strategic and to a certain extent less inclusive than the other plans, but it does facilitate a systematic approach to addressing each 'group' over a period of time.
Some organisations still find that addressing inequality and discrimination from a gender perspective, will help to influence the wider programme on diversity. This school of thought suggests that the prejudices and discrimination relating to women are more deep rooted and have been prevalent for a longer period of time. Hence, progress in this area will be seen as considerable success and help to generate broader engagement in the other strands of activity.
In a lot of cases, organisations adopt a combination of the three types of plans, with the process and population plans working quite well together.
However, a plan is nothing more than a set of papers or a few spreadsheets. The activity behind the plan is the important element and it is the leading-edge organisations which successfully move from strategy to implementation that are benefiting in terms of employer brand, retention and reputation.
Processes plan
Diagnosis and audit Policy development Training, communication and education Accountability Measurement Resources |
Each strand of diversity work is considered under each process, but the emphasis is very much on business process rather than specific strands (eg, race, disability, work-life balance, etc. A full example of this type of plan is outlined later.
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Diversity policy development
A key part of the diversity strategic plan is the development, sign-off, and communication of the actual organisations policy on diversity.
The policy will generally be added to the organisations staff handbook or rules. Ideally, through the audit that has been undertaken, all HR policies and procedures will have been updated and amended where necessary to incorporate the spirit and intent of the diversity policy.
However, the organisation can deliver a strong commitment message both internally and externally through the publication of a policy. Indeed under the Race Relations Amendment Act (2000) and as a result of best practice, many suppliers are being asked to submit evidence of their policy on diversity as a key part of any business arrangement or evaluation.
Populations plan
Race Disability Work-life balance Sexual orientation Religion Age |
Legislation, in particular, has and
will necessitate greater attention to the areas of work-life balance,
religion, sexual orientation and age and organisations can no longer
afford to consider these areas as 'secondary'. |
What is included in a diversity policy?
A policy has a number of objectives and will generally contain information relating to:
Diversity audits
Why undertake an audit?
Many organisations will launch into a programme of diversity work without really knowing where they are in terms of present practice, policies and perceptions. In some cases, organisations will be unable to break down the composition of the workforce which causes considerable difficulties when trying to benchmark progress later on.
Only by knowing the starting point for this strategy, can progress be tracked and measured and hopefully 'favourable' reports can be submitted to the board and senior management teams.
Similarly, to commission a range of diversity training programmes without establishing the issues that need to be addressed flies in the face of good HR practice as well as wasting considerable amounts of money.
A diversity audit is a picture in time. It will present a realistic and hopefully honest picture of the way the organisation is working and what employees, customers, communities, and shareholders think of it. To continue to add value to management reporting, an audit exercise should be repeated ideally every two to three years to identify the 'gains' and the 'losses' to ensure the strategic diversity plan addresses the areas the audit says it should be doing.
Who carries out the audit?
Audits can be done internally, by external input or a combination of both. However, as is outlined below, to tease out some real issues from employers may necessitate some independent and confidential third-party input.
The most robust audits tend to be a mix of internal data cleansing and collection combined with confidential external input. When deploying consultants to undertake audit activities, it is worth establishing their expertise in this area. Audits are not merely asking people questions - the eliciting and interpretation of data is a much broader skill.
How long do audits take?
It will depend on the breadth and the depth of the research, but generally two months should be allowed from the start to the production of an audit report.
What activities are included in audits?
While specific organisations will have specific audit tasks to be conducted, a general audit will usually involve some or all of the following activities:
Audit activities
What is the output from an audit?
The audit findings will be analysed and interpreted and then factored into an overall report which will outline:
It is not sufficient to have a report that outlines the outputs from the research. This is obviously a key element, but the purpose of the audit is to act as a springboard and catalyst for action.
If part of the audit has been conducted by external consultants, an organisation needs to maximise the consultants knowledge of the diversity climate in the sector and the community, to establish comparative positions in terms of benchmarking. Recommended actions and priorities for action should be a major part of the audit report.

Conducting the audit
The structure of the audit will vary, but the following is a guide to help plan the content and framework, whether this is conducted internally or externally.
Populations
Data relating to workforce composition is the fundamental starting point to the audit. The following data should be obtained (and wherever possible retrieved annually for the past three years.
Checklist for management data
1. Breakdown of workforce composition
2. Above data categories broken down into varying lines
3. Maternity leavers and returners
4. Turnover of staff groups listed in 1. and exit interview data
5. Internal selection and promotion data (applications, interviews, appointments)
6. Training and development programme attendance
7. Breakdown of disciplinary and grievance cases
8. Allegations of harassment, bullying (formal and informal)
9. Number of applications to Employment Tribunals
10. Attendance at positive action development programme if applicable
11. Number of applications to apply for flexible working (both carers and non carers)
12. Nominations for fast track management schemes, programmes
13. Performance appraisal ratings and rankings
14. Pay management data
15. Absence, sickness data (reported in specific groups or business units)
Ideally, the above data should be obtained from the overall organisation and individual business functions. This helps to analyse trends, and benchmark those areas where there are particularly good or bad practices or management styles.
Policies
Even the most up-to-date HR and diversity manager, will benefit from having another pair of eyes run the slide rule over policies and procedures. In the majority of cases, policies will only require tweaking slightly to accommodate amendments to legislation, but many require some significant work to bring them up to leading-edge standards - sometimes the obvious is overlooked (ie, the earlier reference to gender reassignment under the Sex Discrimination Act).
The next section (Implementing diversity in practice) will outline some best practice hints and tips which in some cases relate to the following policies. As a result, in this section we only list the typical policies that would normally be looked at in some detail.
Policy and process checklist
Policies relating specifically to an organisation's stance on race, disability, gender, age, religion and sexual orientation will be looked at if available. Increasingly, however, organisations appear to be integrating these policies into the mainstream HR practices listed above so that they reflect an inclusive approach and do not marginalise any individuals or groups of individuals.
When examining the above policies, the content should be compared with best practice equal opportunities standards and professional codes that have been produced. Essentially, this review will ask:
Practice
The most advanced organisations generally agree that to have a full set of well-written and nicely presented policies means very little in reality if the policies are not being implemented in practice. Indeed, comprehensive, leading-edge policies can sometimes work against an organisation if the reality experienced by employees is significantly different.
The 'practice' element of an audit tests out the reality and effectiveness of the policies listed previously.
What is the purpose of auditing practices?
What happens when auditing practice?
Interviews are undertaken with the stakeholders, owners, or champions of the policy in question, and with people who have been through the process. The interviewer is attempting to elicit feedback about the practical side of the policy and if it is aligned with the design. The interviewer will collect structured evidence, sound bites and data to enable comparisons to be made.
While sometimes difficult to identify, people who have left the organisation are a powerful source of feedback. Provided the interviewer can control the interview to concentrate on objective data, the interviewee is usually well positioned to give some very powerful feedback.
We can see that the feedback from the practice interviews is significantly at variance from what the policy says should be happening. Not only does this present elements of risks and bad practice to the organisation, but if this is the feeling generally across the employee base, this can have serious implications for morale and motivation. From the above example, we can see that already the following needs are emerging:
Outputs
When this exercise is repeated across a number of policies, there tend to be themes and trends which emerge. The auditor needs to ensure there is objectivity in answers given and that samples are sufficient enough to have credibility and validity.
Example policy v practice audit
Policy and Process |
Feedback from Practice interview |
All vacancies will be advertised internally before being published externally |
Occasions
where jobs not advertised as Head of Department feels nobody is suitable
internally |
All vacancies must be communicated to individuals on maternity, parental leave. |
Individuals are unaware of vacancies that (a) they may be interested in and (b) may affect their own positions.* |
Interviews are conducted by a mixed panel of trained assessors. |
Individuals
approached 'unofficially' to express interest in positions and briefed
unofficially beforehand. |
Assessors are
trained in cross cultural awareness to ensure objective assessments
undertaken. |
Assessors misinterpret cultural traits and characteristics which affect rapport, communication and interpretations of answers being assessed. |
Perception
What is covered under an audit of perception?
For a lot of people, perception is reality and therefore exploring people's perceptions regarding diversity provides some very powerful and meaningful feedback. The perception element of the audit allows the organisation to get a feel as to how employees feel about:
What are the outputs from work in perception?
For the organisation it is a reality check about specific areas of equality and diversity within the organisation. It may have established what should be happening and how it is being applied, but this area allows the employees to feedback some reality to the policy and procedure designers.
There may be individual, departmental and organisational issues that emerge and the auditor will need to be skilled at collating key themes and issues. For example, the perception element may reveal that the organisation has a long-hours presenteeism type culture where employees are rewarded for the hours they work rather than the work they produce. This may contradict strongly with the recently launched flexible working policy and necessitate some thinking regarding effecting behavioural and attitudinal change in senior managers.
Similarly, there may be practices unearthed in interviews which put the organisation at significant risk with regard to legislation and compliance.
What methods are used to gather people's perceptions?
A range of techniques are available to gather this information:
Gathering employee perceptions through these techniques is obviously critical and the tips and techniques to conduct these activities are outlined as follows:
Tips for focus group discussions
Tips for survey questionnaires
Ensure there is a top-level communication either before or to accompany the distribution of the questionnaire. This reasserts the top-level commitment and clarifies the purpose of the survey.
If possible, allow the survey to be undertaken:
The percentage response rate will be considerably higher if different options are made available.
Take the opportunity to collect demographic data from respondents while ensuring the utmost confidentiality regarding responses.
Separate the survey into convenient sections as this assists with breaking down the final report and allows further benchmarking. Typical areas could be:
Keep the questions/statements relatively short and make sure the language is commensurate with the organisation.
Allow space on the response form for additional comments and sound bites which can be factored into the overall report.
Tips for One to One Interviews
Target interviewees specifically in relation to their role, expertise and influence within the organisation.
Interviews are usually with more senior representatives, but they are excellent means of talking to specific individuals, eg, union representatives, diversity council members, chairs of positive action groups, and so on.
Manage the interview so that views regarding future strategy and activity is elicited and factor this into discussions with the chief executive and other senior operatives.
Obtain specific evidence or data from interviewee regarding their view on diversity management (ie, the reasons for turnover of senior ethnic minority employees, backed up with evidence).
Diversity audit summary
In summary, the perception data, policy review and practice interviews offer a broad and mostly objective analysis of exactly where the organisation is across the spectrum of equality and diversity. The audit report that results should be a comprehensive and rounded appraisal of the strengths and weaknesses of the organisation. Perhaps more importantly, it needs to outline the actions that are needed and the relative priorities of those actions.
Summary
Examples of Diversity Vision Statements
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Strategic Diversity Plan for XYZ Ltd
Area |
Objective |
Activity |
Timescale |
Accountability |
Leadership and vision |
To identify a senior level champion for leading the diversity strategy |
Establish meeting with chief executive to outline Business case and competitor activity |
October 2004 |
Diversity manager |
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To secure top level ownership and sponsorship for planned programme |
Educate chief executive on diversity context in conjunction with the business objectives |
October 2004 |
Diversity manager |
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To develop and cascade a diversity vision statement |
Present headline position and plans to board members to secure buy in at early stage |
November 2004 |
Chief executive Diversity manager |
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Draft vision statement presented to board and chief executive for sign-off |
November 2004 |
Head of communications |
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Statement cascade through team briefing process with support video material |
December 2004 - January 2005 |
Diversity manager |
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Establish relationship with key players in Diversity field for chief executive to network and position |
January 2005 |
Diversity manager, Head of public relations |
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Prepare chief executive briefing and presentation to Senior management conference together with top-line plan for next three years activity |
February 2005 |
Head of communication, Diversity manager |
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Produce 'checklist' for chief executive for discussion areas on regional visits |
February - March 2005 |
Diversity manager |
Audit and Analysis of Organisation |
To establish the present position of the business in relation to compliance and diversity best practice |
Undertake a full audit in relation to policies and procedures; Practice of policy; Perception of policy and process |
December 2004 |
Diversity manager |
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Review all the processes to establish position re. compliance and best practice |
January 2005 |
External input |
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Conduct a full questionnaire audit across the organisation, focusing on specific areas; Leadership; Policies; Recruitment, selection work-life balance culture; Training and development |
January - February 2005 |
External input |
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Undertake 1:1 interviews with key leaders and stake holders to establish leadership credentials and input into new strategy document |
February 2005 |
External input |
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Facilitate focus groups across groups to establish perception of employees in relation to key areas from questionnaire |
February 2005 |
External input |
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Obtain workforce metrics and compare with sector and best practice organisations |
March 2005 |
Diversity manager |
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Produce a risk analysis report for senior board members |
Produce a full audit report from all data obtained; Report to outline: Risks in organisation; Potential opportunities; Best practice standards; Gap for action; recommendations |
April 2005 |
External input Diversity manager |
Policy Development |
Publish a robust engaging policy and cascade across organisation |
Benchmark existing policy statements from other organisations and advisory groups |
March 2005 |
Diversity Manager via external networks |
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Develop policy which outlines: Vision; Scope |
March 2005 |
HR Policy Manager |
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Responsibility; Accountability; Measurements |
April 2005 |
Head of Communications |
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Cascade new policy with chief executive endorsement through Business Briefings |
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Arrange pre launch briefings for HR population |
April 2005 |
Diversity Manager |
Training and education |
To increase general awareness amongst the workforce to understand: Equality and Diversity; Business Case; Personal bias; Real case studies |
Conduct a full training needs analysis relating to the understanding and management of Diversity |
April 2005 |
Training Manager |
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Consult key stakeholders and players on the organisational learning requirements |
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Training Manager |
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Evaluate suppliers training and secure budget for training design and delivery |
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Integrate diversity into mainstream training and development programmes |
May 2005 |
Diversity manager |
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Evaluate bespoke online education packages for integration into education programme |
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Training manager |
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Establish education programmes for |
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Diversity manager |
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Senior management/ board members |
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Middle and functional line managers |
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Broader employee base External Input |
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To effect behavioural change in individuals to reinforce the principles of inclusivity |
Develop programmes which move from awareness to behavioural change |
July 2005 |
Management development manager assessment team |
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Integrate Diversity competencies into development programmes and selection, assessment processes |
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Communication & consultation |
To develop a sophisticated ongoing communications plan to support the roll out of the diversity strategy |
Establish key lines of communication across the business through consultation with key stakeholders |
February 2005 |
Head of communications and diversity manager |
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Undertake audit of existing communications channels to ensure compliance and inclusivity is assured briefings cascades publications, reports, intranet, website |
March 2005 |
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Ensure communication imagery and graphics are inclusive and reflect the words within the documentation |
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Distribute top level communications plan to senior management teams for briefings to teams |
February 2005 |
Diversity manager |
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Develop 'reporting back' communication lines to ensure feedback is channelled to top management |
March 2005 |
Head of communication |
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Ensure mainstream business communication (annual update, reports, etc) reinforce the inclusive messages and become mainstreamed into day to day processes |
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Head of communication |
resources |
To ensure required resources are available with the skills and profile to help roll out the diversity programme |
Establish formal reporting lines for monitoring progress against targets and objectives |
February 2004 |
Lead champion or chief executive |
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Undertake feasibility study into new diversity support role against decentralisation of activity into the business line |
February 2004 |
Diversity manager |
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Select and establish a diversity steering council with representatives from across all parts of the organisation. Identify and appoint functional diversity champions to report progress to diversity council on quarterly basis |
March 2004 |
Chief executive Diversity managers |
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Secure financial sign off from chief executive to enable following activities to be undertaken: Sponsorship and networking; Communication and training programme |
April 2004 |
Diversity manager and head of finance |
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Adjustments to existing materials and processes |
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Reasonable adjustments to comply with DDA best practice requirements |
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Measurement |
To ensure an effective and reliable database and tracking system which enables measurement of progress to take place |
Capture all available workforce metrics from existing database for use as benchmark with sector companies, demographics and best practice standards. To include selection promotion, turnover, and standing data for: Gender Race; Disability; Flexible working; Age; Sexual orientation; Religion if applicable |
January 2005 |
HR planning manager |
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Agree with chief executive/board and diversity council the aspirational targets for the workforce composition over five year period |
February 2005 |
Chief executive/council members |
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Establish formal measurement tools to assess climate in the organisation; Regular staff surveys; 360 feedback mechanisms; analysis of exit interview data; Diversity focus groups and 1:1 Interviews |
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HR manager and head of communication |
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Develop relationships with external benchmarking bodies to assess progress, eg, Race for Opportunity; Opportunity Now; Employers Forum on Disability |
March 2005 |
Diversity manager |
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Evaluate network fairness (both in and out of sector) to assess value for benchmarking purposes |
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Diversity manager |
external profile |
To profile the organisation as a 'best of class' in diversity to enhance the brand and reputation |
Select appropriate membership of organisations in order to network, exchange best practice and generally raise profile |
January 2005 |
Diversity manager |
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Build relationship with trade, local and national press to develop external image and to position organisation as leading edge |
February ongoing |
Head of public relations/chief executive |
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Market the organisations key representatives onto the HR/Diversity Conference circuit in order to present case studies and capture external best practice |
April 2005 |
Head of PR and diversity manager |
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Develop relationships outside the HR press sector in order to mainstream the Diversity context into business |
Ongoing |
Chief executive, Diversity council members |
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Raise profile and sponsor tables at professional networking dinners and conferences |
When available |
Diversity council |
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Submit applications for Awards in Diversity and HR. Acts as good profile and excellent benchmarking tool |
Annually |
Diversity manager |
XYZ Ltd is fully committed to the elimination of unlawful and unfair discrimination and values the differences that a diverse workforce brings to the organisation. We will not discriminate on the grounds of race, gender, disability, nationality, religion, age, sexual orientation, family status or any other irrelevant factor and will build a culture that values meritocracy, openness, fairness and transparency. All employees are responsible for the promotion and advancement of this policy and any actions, words or behaviour that transgresses the policy will not be tolerated and will be dealt with in line with XYZ Ltd disciplinary policy. Objectives relating to fair and inclusive practices will be integrated into all employees' performance indicators and will form an integral part of performance reviews throughout the year. The policy is applicable to all employees, clients, communities, suppliers, contractors whether on a temporary or permanent basis. The policy will apply to all processes relating to employment and training and in any dealings with customers and clients. Decisions relating to customers and communities will be based on business related criteria only and any irrelevant information will not form part of the process. The policy will be reviewed on an ongoing basis to reflect changes in the law, demographics and internal business requirements. Progress relating to the policy will be recorded annually and a full report will be presented to the senior management team to debate progress and review the policy status. The board and senior management team of XYZ Ltd, fully endorse this policy and see it as a critical part of the overall business strategy in order to achieve our business objectives of being: "The first choice for employees, and the leading service provider to our clients and community." Diversity will add value and richness
to the organisation and XYZ Ltd will value and celebrate this diversity of
our employees and the communities we serve. |
One stop guide to managing diversity: other sections Section 1: Why is diversity a
priority |