Six steps to embedding a diversity and inclusion strategy

Author: Sheila Attwood

Having a diverse and inclusive workplace is important not only ethically but also for improving employee morale, boosting innovation and enhancing business success. We set out six practical steps that employers can take to embed diversity and inclusion in the workplace.

While coronavirus has created many employment challenges, employers must remain committed to achieving diversity and inclusion. It is not enough for employers to express their commitment to diversity and inclusion in their mission statements and policies.

Employers must ensure that the concept is embedded in their organisations and that their equality, diversity and inclusion policies are implemented fully and reviewed regularly.

Equality, diversity and inclusion survey
Research finds that equality, diversity and inclusion is firmly on the agenda for the majority of respondents, with 95.9% undertaking equality, diversity and inclusion initiatives in 2022/2023.

1. Train people managers in diversity and inclusion

Line managers are responsible for a wide range of matters including allocating work, setting goals and targets, conducting appraisals, managing performance, monitoring sickness absence and dealing with disciplinary and grievance issues. Unfair (and possibly discriminatory) treatment could occur when they are carrying out any of these functions.

A working knowledge of discrimination law is crucial to the successful functioning of any organisation. It is also something that managers will need to draw on to help create and maintain an environment in which employees are treated fairly.

Organisations should not assume that discrimination will not occur as long as everyone is treated the same. Employers may have to treat people differently to comply with the law.

Training: Discrimination law - the basics: discriminatory behaviour
Training: Discrimination law - the basics: protected characteristics

2. Be aware of protected characteristics - but think beyond them

The Equality Act 2010 prohibits discrimination "because of" a protected characteristic. The term "discrimination" has a very specific meaning in a legal context because it occurs only when it is because of a protected characteristic. Bad treatment that is not connected to a protected characteristic is not discrimination.

The nine protected characteristics
Gender reassignment
Marriage and civil partnership
Pregnancy and maternity
Religion or belief
Sexual orientation

However, if organisations wish to create a workplace that is equal for everyone, they must go beyond compliance with their statutory obligations. They need to ensure that the opportunities available to everyone to participate and reach their full potential in the workplace are not defined or limited by any personal characteristic, including less visible and obvious forms of diversity.

For example, employers can benefit from having a neurodiverse team and capitalise on the strengths of employees who think and work differently.

However, in order to recruit a diverse workforce, employers will need to demonstrate on their website and on vacancy pages that they are an inclusive employer, and that they welcome applications from people with disabilities and different diversities of all sorts.

Employers should think really carefully about their recruitment processes - from advertisements and application forms to interviews - and not use practices that are going to disadvantage applicants with disabilities.

And when it comes to managing a team that is made up of neurodiverse staff and neurotypical staff, managers should be flexible, adaptable and open to doing things differently through talking, listening and accepting that we are all different, our brains work differently and we might process information differently.

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3. Address your unconscious bias

As part of the commitment to creating and cultivating a workplace that embraces equality, diversity and inclusion, it is important that the whole workforce takes steps to address any negative biases that limit opportunities or creativity, and that can lead to discrimination.

Key case
In Georges v Pobl Group Ltd, an employment tribunal upheld a black employee's harassment claim after she attended diversity training at which the trainer wrote racially offensive terms on a flipchart and staff were encouraged to shout out the most offensive words that they could come up with.

While unconscious biases exist, they do not operate as an excuse to take decisions that the employee can simply attempt to justify as being out of their control. Recognising biases, or allowing others to call them out, means that they are no longer unconscious.

By acknowledging the possibility of bias in a particular situation, employees are more likely to ask themselves whether they are being fair and inclusive.

For line managers, decisions that are taken under pressure, or without sufficient time, are far more likely to allow unconscious biases to operate. This is based on a person's instinctive response to reject any person that might be "different" or present a conflicting view. It is therefore important that line managers take decisions at a pace that allows them to review and reflect, minimising the risk of unconscious bias coming into play.

All conversations held at work, whether they are between the manager and their team, with stakeholders or with clients, must be conducted within a framework of fairness, respect and dignity. Employees should ensure that they are open to the perspectives of others; contrasting viewpoints can minimise automatic biases. Organisations that foster and further conversations about biases to cultivate a culture of proactive measures and reassurances will enable employees to call out biases when they occur.

Training: Unconscious bias
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4. Promote and support employee networks

Employers that wish to promote inclusion can create and support employee networks. Typically, employee networks provide an opportunity for employees with common identities to come together to share experiences, gain peer support and facilitate personal development.

Networks can inform an employer's commitment to inclusion by helping to raise awareness of workplace issues and how different employees can be better supported. Networks also enable the wider workforce to understand the experiences of particular groups and be allies for change.

It is good practice for employers to support employee networks, because they can benefit their members and their organisation. Employee networks can:

  • help employees who are in a minority group develop confidence through access to peers and mentors;
  • help employers wishing to canvass the views of employees on specific workplace issues, for example an employer could consult the members of a network on the design of an employee survey, or for feedback on how the organisation's equality policies are working in practice;
  • help to promote wider understanding of practices and cultural sensitivities by running awareness-raising events for all employees; and
  • provide development opportunities for members, for example skills in chairing or organising events.

In many organisations, senior managers are executive sponsors of employee networks to raise the profile and influence of the networks, and to provide opportunities for members to engage directly with leaders and share issues of concern. Managers should be encouraged to show support for employees who are, or wish to be, involved in an employee network.

Employers could also support different networks that hold joint events to raise awareness of how different identities intersect with each other, and what impact this may have.

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5. Gather, report and act on diversity and inclusion data

Collecting and analysing data on gender, ethnicity, disability and other characteristics helps to identify under-representation in the workplace as a whole and within particular occupations and grades.

Key case
In Furlong v Chief Constable of Cheshire Police, an employment tribunal held that a police force's recruitment process discriminated against a white heterosexual male candidate who was rejected after the positive action provisions in the Equality Act 2010 were applied to a pool of 127 applicants who passed the interview stage.

Monitoring provides employers with a better insight as to whom they are recruiting, who is progressing and who is leaving the organisation. Monitoring at key decision points allows employers to better understand who is being affected (or excluded) by decisions.

Without systematic monitoring, employers are unable to identify where the gaps are in relation to achieving a diverse and inclusive workplace. This provides the evidence to inform priorities for action and provides a baseline for measuring progress.

As well as quantitative data, employers should seek to obtain qualitative data through employee engagement surveys, to gain an insight into the extent that employees feel they belong. Asking employees for their views and experiences of training and development opportunities, management behaviour, the appraisal processes, opportunities for promotion, instances of harassment and bullying, and discrimination and then disaggregating where possible, responses by protected characteristics will highlight inequalities, and provide a focus for action.

Conducting anonymised employee surveys, at least biannually will also enable an employer to see what progress is being made on tackling inequality and bias.

Reporting monitoring data and progress on actions to achieve equality, diversity and inclusion to the board will allow it to discuss the issues identified, determine the strategic priorities and be accountable for the progress. Communicating this information to the wider workforce will encourage buy-in and a belief that the employer is determined to make real and lasting change.

Publishing anonymised monitoring data, for example in annual business reports, will show external audiences including prospective employees that the organisation is committed to equality, diversity and inclusion.

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6. Protect the organisation against discrimination - reasonable steps defence

An organisation has a potential defence to a workplace discrimination claim if it has taken "all reasonable steps" to prevent an employee from behaving in a discriminatory way.

Key case
In Allay (UK) Ltd v Gehlen, the EAT held that the employer's diversity training was not sufficient to amount to a "reasonable steps" defence in a claim of racial harassment committed by one of its employees.

The organisation's equal treatment policies and procedures are particularly relevant here because they demonstrate its attitude towards equality and diversity in the workplace.

Employment policies and practices that are objective, justifiable and transparent are essential in ensuring an inclusive workplace. Robust policies that are consistently applied help new and existing employees understand the behaviours that are expected in an inclusive workplace.

Employers should regularly review the scope, content and implementation of all policies to check that they take account of legislative changes, and good practice, and are free from bias.

However, the policies are of little use if they are left to gather dust in a drawer - they must be actively implemented. Line managers have a key role to play here in ensuring that:

  • their team members know about the policies and understand their implications;
  • they and their team members have received training on the policies together with ongoing training on equality and diversity issues in the workplace; and
  • they have records showing that their team members are aware of the policies and have received the relevant training.

The publication of a diversity policy enables the organisation to send out a strong message of commitment, both internally and externally. Although the diversity policy is a fundamental part of the organisation's diversity strategy, it will be brought to life only if it is reinforced by a focused and structured strategic diversity plan. To do this, the organisation will need to commit to processes in areas including leadership, policy development, training and education, and communication.

Equality, diversity and inclusion (EDI) statement (long form)
Equality, diversity and inclusion (EDI) statement for job advert (short form)