EQUALITY, DIVERSITY &
INCLUSION STRATEGY
2016 - 2020
Proudly delivering excellent homes and services to our
customers and communities
CONTENTS
PAGE
1.
Introduction
3
2.
Strategic Vision
3
3.
Definitions
4
4.
What we have achieved so far
5
5.
Aims of this strategy
7
6.
Strategic objectives
8
7.
Responsibilities & Monitoring
11
Appendix 1: Our equality and diversity requirements
Appendix 2: Resident, board, and employee profiles
Appendix 3: Definitions of protected characteristics
Appendix 4: Definitions of discrimination
12
13
15
16
Page 2 of 16
1.0
Introduction
We own and manage 1,486 homes in Bromley, Croydon, Sutton and Merton.
Our roots are in the local community and have been since 1967 when we were
created to meet a housing need in the community. We are regulated by the
Homes and Communities Agency, overseen by a strategic Board and the day
to day running of the organisation is delegated to the Chief Executive and the
Leadership Team.
We are committed to fulfilling our legal duties as well as compliance with the
relevant regulatory duties and standards. However, we recognise that people
may be discriminated against or disadvantaged because of their ethnic origin,
gender (including gender identity), disability, age, religion, sexual orientation.
As a housing provider and employer, we have the ability to reduce the
disadvantages that some people experience, by making our services more
responsive and accessible for a diverse range of individual and community
needs. We oppose all forms of unlawful and unfair discrimination and will seek
to achieve equality by eliminating discrimination experienced and promoting
social cohesion.
We are committed to listening to our customers and involving them in
development of services which recognise and value their diversity. We also
want our colleagues to feel that in everything they do they are valued and
making a difference.
We understand that our ability to meet these diverse needs is helped by having
a diverse workforce and Board membership, which generally reflects our
customers and which has the appropriate skills and understanding to achieve
our objectives.
This strategy addresses both our statutory responsibilities and our business
plan objective “to ensure that no-one is discriminated against because of who
they are or want to be” under our five year plan “Commitment2020”.
2.0
Strategic Vision
Our Equality, Diversity and Inclusion Strategy supports the delivery of our 20152020 Business Plan “Commitment 2020” and in particular our vision of “proudly
delivering excellent homes and services to our customers and communities”.
Our Business Plan has 5 commitments that were developed for residents and
reflects what our priorities are for the next 5 years.
 We will be valued as an influential and high quality landlord, a forward
thinking employer and a trusted partner in our core communities
 We will prioritise enabling residents to keep their homes and promote
mobility
Page 3 of 16
 We will develop more homes and services for local communities
 We will maximise the quality and value of our homes
 We will deliver continuing efficiencies to achieve improved Value for
Money
Underpinning everything we do is our commitment to equality and diversity,
value for money, social responsibility, adding social value and our core values
of:
3.0
Definitions
3.1
Equality is about ensuring that all people are treated equally. This does not
mean treating everyone the same, but recognising the differences in life
situations, in experience and ensuring that there is equality of opportunity for all
people, taking their needs into account.
We want every person to feel that they are receiving fair treatment and have
equal opportunity and rights, irrespective of their background, income,
circumstances or protected characteristics.
3.2
Diversity means valuing the uniqueness of individuals, celebrating difference
and recognising that everyone through their own mixture of skills and
experience has a valuable contribution to make.
3.3
Inclusion means that every person feels appropriately respected, valued and
welcomed as a customer or colleague.
We recognise that there are many different types of barriers that make people
feel excluded, so we will ensure individuals are being included in our services
and employment.
3.4
Our regulatory and legal requirements for equality and diversity can be found
at Appendix 1.
Page 4 of 16
4.
What we have achieved so far
4.1
Organisational commitment
Leadership: We have signed up to the Chartered Institute of Housing’s Equality and
Diversity Charter along with a new initiative being driven by the CIH “Leading Diversity
by 2020”. This is because we want to deliver a fair and inclusive service that is clearly
focused on achieving positive outcomes for our customers, colleagues, stakeholders
and communities.
Equality Impact Assessments: Equality Impact Assessments (EIAs) are now being
conducted on every new strategy and policy. In addition, to ensure that employees,
the Board and anybody working on our behalf, place equality and diversity at the root
of every decision they make, an equality and diversity comment is included on every
board/committee paper.
Equality & Diversity Champions: We now have two champions in promoting equality
and diversity in all we do, which also includes sharing any best practice with others
and reviewing our equality impact assessment decisions.
Training: Mandatory training of equality and diversity has been delivered to all Board
members and employees.
4.2
Knowing our customers
We have undertaken a significant amount of customer profiling work, particular with
customers who are likely to be impacted by ongoing welfare reforms. Diversity
information captured is now at 100%. This has enabled us to communicate with our
residents by their preferred methods. We are also able to target residents specifically
in areas of interest and do not have a blanket approach. The profiling information we
hold on our residents tells us their age profile, ethnicity and language and a summary
profile of our residents, board and employees is provided as Appendix 2.
This is still an on-going priority for the organisation as the analysis of this data will help
in shaping our services for the future and allow evidence based decisions to be made.
4.3
Customer Care and Satisfaction
Our Customer Care Standards set out our expectation that all our residents are
treated with fairness and respect.
STAR Survey 2015: Evidence shows that our residents remain satisfied with the
overall services they are receiving and the way in which we keep them informed:
 Overall Satisfaction: 87% (86% in 2013)
 Keeping residents informed: 81% (84% in 2013)
 Taking resident views into account: 70% (70% in 2013).
An important element of resident-based research is to put results in a meaningful
context in order to gauge an understanding of how the organisation is performing
within the sector. The most complete set of benchmarks currently available is supplied
Page 5 of 16
by Housemark and, specifically, our London peer-group for general needs housing.
When assessed against this peer group, our performance for overall satisfaction,
repairs and maintenance, and listening and responding to views are all placed in the
upper quartile.
Complaints
We have introduced monitoring of the profile of complainants through a six-monthly
complaints report that goes to the Leadership Team. Over time this will allow us to see
whether any particular diverse groups are disadvantaged by our policies and the
services we provide. This information will in turn allow us to make improvements to
mitigate the risk of any discrimination in the future.
4.4
Customer Engagement
Our customer profiling information allows us to target our residents specifically to
service areas that would be of interest to them and in their chosen method of
communication. Some examples of our targeted services are provided below:
4.5

Our youth engagement initiatives including the Momentum event which
attracted 956 young people in 2015 and the Schools out programme which
attracts over 30 young people every year and enables their parents to either
get a break or continue to work without paying for childcare.

The Horizon programme set up to assist in tackling worklessness has been a
great success and supported 135 residents between 2012 to 2015 through work
placements, apprenticeships, information, advice and guidance sessions and
training programmes.

Procurement and monitoring of front line services – residents have been
involved in all procurement of our main front line services since 2008.

Digital workshops – our residents learn about setting up an e-mail address and
using email confidentially, using the internet safely and protecting themselves
from fraud, using online searches to find out what they are look for, connect
online with us and accessing public and local services. There is also a resident
IT hub set up in the reception for residents to use at any time in office hours.
Partnership Working
Evidence of a commitment to equality and diversity is required from contractors
bidding for tenders as part of our standard tendering process. When carrying out any
procurement a Pre-Qualification Questionnaire (PQQ) is sent to all applicants to check
that they meet minimum standards of eligibility – this includes a requirement for the
contractor to set out their commitment to equality and diversity, and ensures that they
share our business culture.
Page 6 of 16
The PQQ makes it clear that we are committed to equality of opportunity in the
provision of services and aims to deliver services of the highest quality without
discrimination. It also sets out that we strive to ensure that our services are equally
accessible to everyone and appropriate to the differing needs of all sections of the
community.
Some of the above customer engagement initiatives have been delivered through
working with partners. For example, in partnership with Elevating Success we offer
employability skills training. Besides the usual CV updating, interview skills this also
includes confidence building and a Job Support Worker. We also work as part of a
consortium of housing associations and local authorities in the delivery of Momentum
and other community events.
4.6
A skilled and committed workforce
We carry out a biennial employee survey, the results of which shows positive feedback
around equality, diversity and inclusion regardless of their equality characteristics. In
2015 we were awarded Best Companies 1 Star Accreditation.
We keep equality information about all of our employees, make reasonable
adjustments for differences in culture, beliefs or disability and any other protected
characteristics. We have 100% participation of our Equality and Diversity Training.
5.
Aims of this strategy
The overall aims of this strategy are:




To support and develop a culture that values the diversity of our customers,
Board and employees.
To have customers who know about, can easily access and are happy with their
experience of services provided by CCHA
To provide services and communications that are tailored to individual needs
and preferences
To recruit and retain a diverse workforce
The strategy has been developed to support the implementation of our business
objectives 2015-2020. We have consulted with our residents and employees to ensure
that the strategy supports the business to achieve this.
We have consulted with:




Residents
All Employees
Diversity Champions
Leadership Team
Page 7 of 16
6.
Strategic Objectives
We believe in promoting equality and diversity in everything we do. This commitment
is central to our strategy and will support our 2015-2020 business priority to “ensure
that no-one is discriminated against because of who they are or want to be”.
These objectives will strengthen our performance and compliance with the Equality
Act, enable us to focus on achieving specific outcomes, provide clarity on what we are
aiming for and demonstrate our commitment to equality, diversity and inclusion.
1. Encourage a corporate culture where equality and diversity is treated as a
key, integral value for the organisation
We will foster an accessible and inclusive environment for all our employees and
residents through a strong vision and commitment to equality. We should strive to be
a leader on equality, diversity and inclusion in the social housing sector.
We are committed to valuing and developing the skills and abilities of all our
employees to enable them to reach their full potential. We collect profiling information
for employees. We will use the information we hold to ensure our employees are
treated fairly irrespective of their protected characteristics.
Outcomes:






Our governance, leadership structures and workforce will broadly represent the
diversity of the communities we serve.
Our employees, board members and job applicants will receive fair and equal
treatment in recruitment and selection
Our Board and employees will communicate this strategy to the widest possible
audience
Key business decisions, strategies, policies and procedures will be considered
for their impact on key customer groups and actions will be identified to mitigate
the impact on affected groups
All employees will be supported in order to have the right skills and capabilities
to support our culture of equality, diversity and inclusion to colleagues and
partners
Work towards the elimination of harassment, hate crime and domestic abuse,
supporting victims and taking actions against perpetrators
Measures:




An updated Recruitment and Selection Procedure
Mandatory training for employees responsible for recruitment
Equality impact assessment outcomes used to shape service improvement
plans
Provide training for frontline employees on recognising issues such as domestic
abuse and mental health conditions.
Page 8 of 16





Refresher training for board members and employees on equality, diversity and
inclusion every 3 years, maintaining a 100% record.
Carry out a biennial employee survey and act on the results to improve
ourselves as an employer.
No significant differential in satisfaction outcomes for employees across all
diversity strands:
 Exit interviews
 Learning and development programmes
 Opportunities and benefits in the workplace
Roll out mentoring programmes for employees
Complete the 10 challenges as set out by the CIH’s Leading diversity by 2020
campaign.
2. Actively consult our customers to understand better the diversity in our
communities and ensure that their views form an integral part of the decision
making process
We will ensure, where possible, we have the information needed in order to design
our services in an inclusive and accessible manner. We recognise the need to be seen
as a responsive and adaptive organisation in order to provide the best customer care
that we can to our residents.
We collect profiling information from our residents on the protected characteristics.
The provision of personal information is entirely voluntary. Residents are not obliged
to provide personal information to us but the law requires us to gather this information
if we can.
We are committed to inclusion by removing barriers that hinder our residents’ voices
being heard. We have long understood the value of involving our residents in decision
making and providing a variety of options for involvement so all residents have the
opportunity to engage at a level they are comfortable with. This will allow us to help to
ensure residents are included in the key areas that impact on them.
Outcomes:




Continue to ask our residents about themselves and their household to
understand their needs, tailor our services and help us comply with equality law
Use the profiling information to ensure all residents have access to our services,
to check that all our residents are satisfied with our services and to drive service
improvements
Offer effective ways for all of our customers to engage with us, especially those
from underrepresented groups
Have the systems in place to allow us to use our profiling information to
enhance the inclusion of all our residents
Page 9 of 16
Measures






Maintaining 100% customer profiling
Develop process to improve range and accuracy of data held, for example,
email addresses and mobile phone numbers, with an increase of 20% of data
held
Develop process to gather profiling information of those who engage with
resident events and other community investment initiatives
50% resident attendance at all action days
40% response from residents through all survey and consultation engagements
Improvement in satisfaction of listening to residents views and acting upon on
it to 75% from 70%
3. Enhance opportunities for our residents through job training and educational
opportunities as well as promoting engagement through other mechanisms.
We recognise that some of our residents are in need of a diverse range of support and
that unemployment is a key issue and barrier when addressing inclusion. We therefore
partner with like-minded organisations to help our residents overcome this barrier.
We also recognise that online engagement is a growing mechanism for our residents
to engage and access the services they need.
Outcomes:








Continue to build inclusive community engagement structures by providing
training and capacity building and actively reach out to and encourage residents
from underrepresented groups to become involved
Assist our residents in finding volunteering placements, work opportunities and
access education
Take every opportunity to increase engagement with young people through
social media and community events
Look at innovative ways to build community cohesion on our estates
Look at innovative ways on how to engage with those in street properties
Maintain and increase digital inclusion for our residents
Maximise the use of technology and digital platforms
Have systems in place for residents to engage interactively
Measures:



Analyse the satisfaction rates for our street properties in isolation and identify
any areas where the satisfaction is significantly lower than the overall
satisfaction in order to address these issues specifically with these residents.
Identify and deliver one project per year funded through the President’s Fund
to build community cohesion
Delivery of the digital inclusion objectives in the community investment strategy
Page 10 of 16




Work experience placements for 2 CCHA resident’s and/or resident’s children
Increase in number of our digital workshops and employability skills workshops
delivered with partners
20% of increased hits to our website and Facebook pages
Ability to pay rent, book a repair, book events online
4. Influence our contractors, partners, consultants and suppliers to meet the
highest standards of equality and diversity
We will ensure that our partnerships with stakeholders are reflective of our strong
vision of equality, diversity and inclusion. We also recognise that our approach to these
partnerships should be done in a way that ensures equality and diversity is at the heart
of all we do.
Outcomes:




Use our purchasing power to work with small and medium enterprises
whenever possible.
Our values on equality, diversity and inclusion will be reflected in our
procurement processes and outcomes
Our partners will reflect our values and also have the commitment to support
their own employees in embodying these.
Continue to work with different stakeholders, for example, housing
associations, local authorities and other not for profit organisations to promote
and deliver further opportunities for the diverse groups within our communities.
Measures:



7.
A Procurement Policy that reflects our strong vision of equality, diversity and
inclusion
Adherence to our Procurement Policy
Mears commitment 100 residents into work related initiatives over duration of
contract (by 2025), 1 apprentice per £1million of spend
Responsibilities & Monitoring
Board members, employees, residents, other customers and stakeholders including
contractors all have an important part to play in promoting equality, diversity and
inclusion. We require all to recognise and discharge their responsibility for contributing
to the success of this strategy.
The Chief Executive has responsibility for ensuring the strategy is implemented across
the organisation. Performance reports on the progress of our objectives will be
provided to the Board on a yearly basis.
This strategy will be reviewed every three years or more frequently if required.
Page 11 of 16
Appendix 1:
Our Equality and Diversity requirements
Regulatory
We recognise the importance and value of involving our customers and the outcomes
placed on us to do so, from the Homes and Communities Agency, our regulatory body.
Specifically:
Customer service, choice and complaints
 Provide choices, information and communication that are appropriate to the
diverse needs of our customers in the delivery of all standards
 Have an approach to complaints that is clear, simple and accessible and that
ensures that complaints are resolved promptly, politely and fairly
Understanding and responding to the diverse needs of customers
 Treat all customers with fairness and respect
 Demonstrate that we understand the different needs of our customers, including
those with additional support needs.
Legal
We are legally obliged to adhere to the requirements of:
Equality Act 2010
As a Social Housing Provider the Equality Act 2010 places a general duty upon us to:
 Eliminate unlawful discrimination, harassment and victimisation and other conduct
prohibited by the Act
 Advance equality of opportunity between people who share a protected
characteristic and those who do not
 Foster good relations between people who share a protected characteristic and
those who do not
The Equality Act explains that having a due regard for advancing equality involves:
 Removing or minimising disadvantages suffered by people due to their protected
characteristics
 Taking steps to meet the needs of people from protected groups where there are
different form the needs of other people
 Encouraging people from protected groups to participate in public life or in other
activities where their participation is disproportionately low.
Human Rights Act 1998
As a Social Housing Provider, we need to consider three articles contained within the
Human Rights Act in providing all our services:
 Article 6 – right to a fair trial
 Article 8 – right to respect for private life, family life and the home
 Article 14 – prohibition of discrimination
Page 12 of 16
Appendix 2
Our resident, board and employee profiles as at March 2016
AGE
Residents
Board
Employees
ETHNIC
ORIGIN
Residents
Board
Employees
GENDER
1624
3%
0%
3%
2534
10%
0%
18%
3544
12%
0%
32%
White
4554
32%
25%
29%
5564
14%
75%
18%
BAME
38%
62.5%
60.6%
5%
0%
2.6%
Male
61%
37.5%
76%
7584
6%
0%
0%
Other
26%
12.5%
36.8%
Female
Residents
Board
Employees
6574
9%
0%
0%
39%
62.5%
24%
85+
3%
0%
0%
Unknown/
Didn’t
Answer
11%
0%
0%
Prefer not to
answer
/unknown
31%
25%
0%
Prefer not to
answer/unknown
0%
0%
0%
RELIGION
Residents
Board
Employees
RELIGION
No religion
11.90%
Christian
35.20%
Buddhist
0.20%
Hindu
2.09%
Jewish
0.13%
21.1%
Muslim
60.5%
Sikh
0%
Other
0%
Unknown
Residents
Board
Employees
2.70%
0.27%
0.40%
0%
Prefer not
to say
5.41%
0%
0%
2.6%
10.6%
42.65%
100%
5.2%
Page 13 of 16
SEXUAL
ORIENTATION
Residents
Board
Employees
SEXUAL
ORIENTATION
Residents
Board
Employees
DISABILITIES
Residents
Board
Employees
Bisexual
Gay man
0.07%
0%
Prefer
not to
say
6%
0.3%
0%
Unknown
Gay woman/
lesbian
0.5%
Heterosexual/
straight
56%
Other
0%
86.9%
0%
0.4%
37%
100%
7.9%
5.2%
Yes
No
26%
0%
5.2%
31%
100%
86.9%
Prefer not to
answer/unknown
43%
0%
7.9%
Page 14 of 16
Appendix 3
Definitions of protected characteristics
Age - A person having a particular age (for example, 32 years old) or being within an
age group (for example, 25-34 year olds). This covers all ages, including children.
Disability - A person has a disability if s/he has a physical or mental impairment which
has a substantial and long-term adverse effect on their ability to carry out normal daytoday activities.
Gender reassignment - A person who is proposing to undergo, is undergoing or has
undergone a process to change their gender.
Marriage - A union between a man and a woman or a same-sex couple.
Civil partnership - Legal recognition of a same-sex couple’s relationship. Civil
partners must be treated the same as married couples on a range of legal matters.
Pregnancy - The condition of being pregnant.
Maternity - The period after giving birth. It is linked to maternity leave in the
employment context.
In the non-work context, protection against maternity discrimination is for 26 weeks
after giving birth, including as a result of breastfeeding.
Race - A group of people defined by their colour, nationality (including citizenship),
ethnic or national origins.
Religion - Any religion, including a lack of religion.
Belief - Includes religious and philosophical beliefs including lack of belief (for
example, atheism). Generally a belief should affect life choices or the way you live for
it to be included in the definition.
Gender (sex) - A man or a woman.
Sexual orientation - Whether a person's sexual attraction is towards their own sex,
the opposite sex or to both sexes.
Page 15 of 16
Appendix 4
Definitions of discrimination
Direct discrimination - Treating a person less favourably because they have a
protected characteristic. Example - Refusing a job to an applicant who is perfectly
capable of doing the job because they are judged too old.
Protected characteristics - Age, disability, gender reassignment, marriage and civil
partnerships, pregnancy and maternity, race, ethnic or national origin, religion or belief,
gender and sexual orientation.
Indirect discrimination - When a rule, policy or practice applies to everyone but
particularly disadvantages people who share a protected characteristic. Example Arranging a community event at a venue with a number of steps and no lift. This means
residents who have mobility problems are unable to attend.
Discrimination by association - Direct discrimination against someone because they
associate with another person who possesses a protected characteristic. Example An employer disciplines a woman because she has to take time off work to care for
her disabled child. He has not disciplined any other workers who have had similar
amounts of time off work.
Discrimination by perception - Direct discrimination against someone because they
are thought to possess a particular protected characteristic. Example - A group of
youths congregate near a bus stop and shout homophobic abuse at two men they
believe to be gay as they share a flat.
Harassment - Unwanted conduct related to a protected characteristic that has the
purpose or effect of violating a person’s dignity or creates an intimidating, hostile,
degrading, humiliating or offensive environment. Example - A resident with learning
difficulties is frequently called offensive names by a neighbour. The victim is frightened
and upset by this.
Harassment by a third party - Employers are liable for harassment of employees
based on any of the protected characteristics (other than marriage/civil partnership
and pregnancy/maternity) by individuals who are not employees of the company.
Example - A contractor who calls into the office regularly makes racist remarks in the
hearing of a member of staff who is black. The office manager is aware of this but
does nothing to stop the contractor.
Victimisation - Someone is treated badly because they have made/supported a
complaint or grievance under the equality act or are suspected of doing so. Example
- A member of staff gives evidence to support a claim brought by a colleague that a
manager is sexually harassing her. All the other managers then refuse to talk to her
for supporting the complainant.
Discrimination arising from disability - Someone is treated unfairly because of
something connected to their mental or physical disability. Example - A member of
staff develops a sight problem which means they can no longer read instructions and
they are sacked for this.
Page 16 of 16