Equalities Policy
This policy sets out our commitment to compliance with the Equality Act and the Public Sector Equality Duty.
Equalities Policy 2025 705 KB 14 pages
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Implementation date: October 2025
Review required: October 2028
Contents
- Introduction
- Scope
- Key terms and definitions
- Our approach to achieving our objectives
- Translation
- Legislation and Regulation
- Public Sector Equality Duty
- Equality Impact Assessment (EIA)
- Monitoring and measuring progress: Diversity Data
- Responsibilities
- Forums and employee networks
- Equality monitoring
- Appendix
1. Introduction
1.1. Derby Homes is dedicated to the promotion of equality of opportunity and to removing any discrimination in service delivery, procurement and employment. This is an ambition that we cannot realise alone. To achieve the levels of equality, inclusion and community cohesion we aspire to for our district, we remain committed to working in partnership with organisations and local communities across and beyond our geography.
1.2. We believe in treating everyone fairly and with respect. We see the diversity of our city as a real strength. We want to build strong communities with a sense of togetherness and we want to tackle disadvantage. We also want to build a strong cohesive workforce that reflects the community we serve. We want everyone to be able to reach their full potential and to benefit from the cultural, social, economic and civic strength of our city. We recognise that it’s only by meeting people’s particular needs, having accessible services and a diverse workforce, just like the community we live in, that we will achieve equality.
1.3. The aim of this policy is to ensure that we meet our equality diversity and inclusion commitments and work within the requirements of the Equality Act 2010 by promoting a culture of respect and dignity and actively challenging discrimination.
1.4. Equality lies at the heart of all our work, across Derby Homes – we believe this makes good business sense, is cost effective and makes for a much happier workforce, which in turn results in satisfied customers. It also has an impact on the health and wellbeing of our communities.
1.5. Any Equalities Policy needs equality objectives to work towards. Here are our Statutory Equality Objectives for 2025/2028 demonstrating how we are going to promote equality:
- Improving outcomes: Working to improve outcomes for people with protected characteristics.
- Improving access: Working to improve access to services for people with protected characteristics
- Improving the workplace: Working to create an inclusive workplace that attracts a diverse range of candidates
- Improve the quality and range of equality information: held and used by us, in particular equality monitoring around our services.
- Undertake an Equality Impact Assessment (EqIA) to consider the actual or potential impact of our activities and decisions on people and to remove or reduce negative impacts.
2. Scope
2.1. This policy applies to all colleagues and customers of Derby Homes. It also applies to contractors, agency workers and anyone else engaged to work for Derby Homes.
2.2. This policy may be subject to amendments from time to time, to reflect the changing needs of the business, legislation, and working environment.
3. Key terms and definitions
3.1. Equality is about fair and equal access, ensuring that our colleagues and customers have the same opportunities, regardless of their protected
characteristics or socio-economic status. Whilst equality sets out the foundations to ensure fair and equal access, within this policy we also recognise the importance of equity. Equity is about ensuring that our colleagues and customers have what they need to achieve equal outcomes.
Put simply, equity means understanding that not everyone starts out in the same place and that adjustments may need to be made to ensure fairness, based on someone’s individual needs.
4. Our approach to achieving our objectives
4.1. In plans, policies and practices we will:
4.1.1. Design services that meet the needs of our communities by using
research and consultation and our experience of good practice.
4.1.2. Make sure that our plans, policies and practices do not unfairly
discriminate against people with protected characteristics by doing robust equality impact assessments and acting on the results
4.1.3. Make sure that all our employees, volunteers, customers, residents, partners and contractors are aware of this Equalities Policy.
4.2. In service delivery we will:
4.2.1. Make sure our services are relevant to the people of Derby and take into account people’s and communities’ different needs.
4.2.2. Actively engage with as many sections of the community as possible when we consult about our services.
4.2.3. Celebrate the variety of lifestyles and cultures in Derby
4.2.4. Do all we can to review and monitor our services to make sure they do not discriminate unfairly, and identify where we can improve services.
4.2.5. Make sure we provide services that comply with relevant legislation and statutory codes of practice
4.2.6. Continue developing good practice policies and practices.
4.2.7. Treat all our customers positively, with dignity and respect
4.2.8. Act promptly, investigate and respond to complaints of discrimination, harassment, victimisation and bullying
4.2.9. Analyse and understand findings when things go wrong or when we need to do better.
4.2.10. Listen to our customers to make sure their views are continually
taken into consideration to shape decisions.
4.3. We will treat all customers fairly and with respect and we will expect customers to have the same respect for our colleagues contractors and other customers. We will take action against any customer who abuses or discriminates against a colleague contractor, or another customer in line with our Antisocial Behaviour Policy and Hate Crime Policy.
4.4. In employment we will:
4.4.1. Do everything we can to make sure our workplace is free from
discrimination, oppression, bullying, harassment and victimisation and will act promptly on any complaints.
4.4.2. Strive to recruit and retain a workforce that is as diverse as the
community we serve in all our services and at every level.
4.4.3. Treat all employees, volunteers and job applicants fairly and provide reasonable adjustments when required.
4.4.4. Make sure all our employees and volunteers receive Equality themed training.
4.4.5. Provide our employees with clear information about job selection, training and development and encouragement to reach their full potential.
4.4.6. Provide a safe working environment and demonstrate that we care about the health and wellbeing of our employees.
4.4.7. Make sure that we work to relevant legislation and statutory codes of practice.
4.4.8. Continue to develop good practice employment policies and practices.
4.4.9. Listen to our employees ideas and suggestions for improving services and ways of working, through our employee equality networks.
4.4.10. As a Disability Confident employer, we will guarantee to interview all job applicants with a disability who meet the essential requirements of a role.
4.5. Discrimination bullying victimisation and harassment in employment
4.6. Sexual harassment, harassment and victimisation in employment under the work provisions in the Equality Act 2010
4.6.1. The Act makes three types of harassment unlawful. These are:
4.6.1.1. harassment related to a ‘relevant protected characteristic’
4.6.1.2. sexual harassment and
4.6.1.3. less favourable treatment of a worker because they submit to, or reject, sexual harassment or harassment related to sex or gender
reassignment.
4.7. In partnerships and contracting we will:
4.7.1. Make sure that our partners and contractors have the same values and principles and approach to equality, diversity and inclusion as we do.
4.7.2. Make sure that equality, diversity and inclusion is embedded in any contract specification.
4.7.3. Take appropriate action for any breach of equality requirements and conditions by contractors delivering our services.
4.7.4. Share our knowledge of our diverse communities, their requirements, and aspirations, with our partners and contractors to help shape and improve the services they provide.
4.7.5. Listen to the views of our partners and contractors to help us to improve our work and practice.
5. Translation
5.1. Where needed, translations can be provided by a customer’s advocate such as a family member or support worker with the customer’s consent. For legal or sensitive issues, we will always use a professional translation service if needed.
5.2. We will also translate written documents on request where it is practical and cost effective. If we’re unable to provide the customer’s preferred method or format, we will make sure they understand the information provided by using an alternative where needed, such as audio format.
6. Legislation and Regulation
6.1. The Equality Act 2010 gives individuals protection from discrimination in the workplace and sets a standard for those providing services. The implementation of this policy will help ensure we comply with the general duty of the Act and are able to demonstrate how we will:
6.1.1. Eliminate unlawful discrimination, harassment victimisation and other conduct prohibited by the Act.
6.1.2. Advance equality of opportunity between people who share a protected characteristic and those who do not.
6.1.3. Foster good relations between people who share a protected
characteristic and those who do not.
6.1.4. Promote equality of opportunity and treating everyone with dignity and respect.
6.2. The Act identifies 9 protected groups. These groups have a shared
characteristic and are protected from discrimination under the Act (see also Appendix 1).
6.3. The National Housing Federation Code of Governance 2020 requires boards to demonstrate a clear and active commitment to achieving equality diversity and inclusion in their organisation's activities.
6.4. The Regulator of Social Housing's Tenant Involvement and Empowerment Standard requires us to provide choices, information and communication that are appropriate to the diverse needs of our customers, and to treat customers with fairness and respect.
7. Public Sector Equality Duty
7.1. We are committed to complying with our legal obligations under the Equality Act 2010 and the Public Sector Equality Duty. We will make sure all our employment policies and practises are up to date and that our services are meaningful and accessible for Derby’s diverse communities. We will make sure all our employees, volunteers and contractors are aware of these legal responsibilities in everything Derby Homes or our representatives do.
7.2. We will use our responsibilities under the Public Sector Equality Duty to do all we can to encourage other organisations to work to the Equality Act so that the people of Derby experience a consistent approach to equality in the city.
7.3. The Public Sector Equality Duty requires us as a public body to have ‘due regard’ to:
7.3.1. eliminating discrimination, harassment and victimisation and any other conduct that is prohibited by the Equality Act
7.3.2. advance equality of opportunity
7.3.3. foster good relations between people who share a relevant protected characteristic and those who don’t.
7.4. The Duty also requires us to take into account disabled people’s impairments, when making decisions about policies and services, as the law recognises that disabled people’s needs may be different from the needs of non-disabled people. This might mean making reasonable adjustments or treating disabled differently to non-disabled people to meet their needs.
7.5. Having ‘due regard’ means:
7.5.1. removing or minimising disadvantages suffered by people due to their protected characteristics
7.5.2. taking steps to meet the needs of people with certain protected characteristics where these are different to from the needs of other people
7.5.3. encouraging people with certain characteristics to participate in public life or in other activities where the participation is disproportionately low.
7.6. The Public Sector Equality Duty also has specific requirements that we are legally required to comply with and these are to publish:
7.6.1. equality information about our employees and people affected by our policies and practices.
7.6.2. one or more equality objectives at least every four years to help us achieve the requirements of the general Public Sector Equality Duty.
8. Equality Impact Assessment
8.1. Equality Impact Assessments (EIAs) are an effective tool to help organisations meet their Equality Act responsibilities. An Equality Impact Assessment should be undertaken for any new or reviewed policy procedure or programme that may affect our colleagues or customers. This will ensure that any negative or differential impact on those with a protected characteristic is mitigated. Our EIA processes will take into consideration factors such as our colleague and customer diversity data, research findings and survey data. If an EIA shows that a current policy procedure or practice is having an adverse impact, or if opportunities arise which would allow a greater equality of opportunity to be promoted, we will ensure that the policy procedure or practice is revised.
9. Monitoring and measuring progress: Diversity Data
9.1. Collecting colleague and customer diversity data enables us to measure and report our performance and progress towards our EDI goals. The purpose of collecting diversity data is to look for differences between groups, identify trends over periods of time, investigate the reasons for these differences and put appropriate actions in place.
9.2. We will collect diversity data in a variety of ways. This will include collecting data by protected characteristic for our colleagues and customers. We will explain why we collect this data and how we will use it to understand how fair and inclusive our organisational practices are.
10. Responsibilities
The Managing Director and Board Members are responsible for promoting Derby Homes approach and commitment to equality and diversity across the organisation and in the wider community, recommending changes and improvements where necessary.
The Managing Director, Executive team, Heads of Service, Managers and supervisors have responsibility for developing a culture that promotes equality and values diversity in employment and in service delivery. They are also responsible for making sure that this policy is fully implemented and monitored.
We will make sure that all our employees are aware of their personal responsibility for making sure that the principles of equality and diversity are met. This applies to their behaviour at work and in some situations even when they are not at work All employees, volunteers and contractors must make sure they do not:
- discriminate against anyone
- persuade or pressure another employee to discriminate
- harass, bully, abuse or victimise other employees, volunteers or customers for any reason
- condone harassment.
If an employee does not follow the principles of this Equality Policy, then this will usually be dealt with under our Disciplinary Procedure.
We will make sure that our partners and contractors are aware of and comply with this Equality Policy.
11. Forums and employee networks
Derby Homes Equality Diversity and Inclusion Forum act as our critical friend in making sure equality and diversity stays at the heart of everything we do - when we don’t get things right, we learn from this and try not to make the same mistake again.
12. Equality monitoring
12.1. Equality monitoring is collecting information about employees, job applicants and customers. It’s a sophisticated way of us better understanding our organisation, who are our employees, who applies for jobs and who are our service users – it can also tell us who are not using our services or who are not applying for jobs with us.
12.2. We collect equality information on our employees and job applicants and on certain service areas such as feedback and complaints and some other areas of service delivery where equality monitoring is a statutory requirement.
When we do customer surveys and consultation exercises we ask people to give us their equality information. We do this not because we are nosy, but because we genuinely want to make things better and filling in equality monitoring forms helps us to do this.
12.3. We ask equality questions to make sure we are being fair and that people from all backgrounds are represented and so that we can make our services better by targeting them at the right people.
12.4. There are nine protected characteristics under the Equality Act and so we feel it is important that where appropriate when we ask monitoring questions, we use all nine of these.
12.5. When we receive equality monitoring forms we have strict laws to make sure we keep the information safe and secure and only use the information to make our services and employment areas better
12.6. We will publish statistics on the nine protected characteristics.
12.7. As part of the Assurance Statement to the Regulator, we will include reference to our approach to equalities.
Appendix
Appendix 1
Equality Act 2010 Protected Characteristics
The Equality Act 2010 Protected Characteristics are:
Age – the Act protects people of all ages. However, different treatment because of age is not unlawful. For example, direct or indirect discrimination can be justified if it can be demonstrated that it is a proportionate means of meeting a legitimate aim. Age is the only protected characteristic that allows employers to justify direct discrimination – for example the age restrictions which apply to joining the Armed Forces.
Disability (mental and physical) – the Act makes it easier for a person to show that they are disabled and therefore protected from disability discrimination. Under the Act a person is disabled if they have a mental or physical impairment which has a substantial and long term adverse effect on their ability to carry out day to day activities, such as using public transport, answering telephones etc. As an employer and service provider we have a duty to make reasonable adjustments for colleagues and customers to help them to overcome any disadvantage associated with their disability.
Gender Reassignment – the Act provides protection for someone who proposes to, starts, or has completed a process to change their gender. Time taken to undertake appointments relating to gender reassignment is also covered by the Act.
Marital or Civil Partnership Status - The Act protects those who are married or in a civil partnership against discrimination.
Pregnancy or Maternity – The Act protects a woman against discrimination on the grounds of pregnancy and maternity. Any absence due to pregnancy related illness must be considered when making employment-related decisions.
Race – The Act protects individuals against discrimination on the grounds of their race.This includes colour, nationality and ethnic or national origins.
Religion or Belief – The Act protects individuals against discrimination on the grounds of their religion. This also includes an individual who has no religion. A religion must have a clear structure and belief system to be protected by the Act. Belief also means a clear and structured belief as well as no belief. Political or scientific beliefs are not covered by the Act.
Sex - both men and women are protected under the Act.
Sexual Orientation - the Act protects bisexual, gay heterosexual and lesbian people from discrimination.
Appendix 2:
Equality Act 2010 – definitions of discrimination harassment and victimisation
Direct discrimination. This occurs when someone is treated less favourably than another person because they have a protected characteristic.
Associative discrimination. This is discrimination against a person because they have an association with someone with a particular protected characteristic.
Perceptive discrimination. This is discrimination against a person because the discriminator thinks they possess a protected characteristic, even if they do not.
Indirect discrimination. This occurs when a policy, rule or procedure applies to everyone but has a disproportionate impact on someone with a protected characteristic.
Harassment. The Act defines harassment as ‘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'. Bullying is a form of harassment, usually persistent, and often related to an abuse of power or the use of unfair sanctions.
Third party harassment. The Act makes an organisation potentially liable for the harassment of an employee by those it does not employ. An employer will only be liable if the harassment has occurred on at least two previous occasions, and if the employer knows that it has taken place and has not taken reasonable steps to prevent it from being repeated.
Victimisation. This occurs when an employee is victimised because they have made or supported a complaint or raised a grievance or they are suspected of doing so.