Workforce progress report 2019

The Equality Act 2010 sets out Public Sector Equality Duties. We must comply with the duties and have due regard for the need to:

1. Eliminate unlawful discrimination, harassment, victimisation and other conduct prohibited by the Act.
2. Advance equality of opportunity between people of different groups or 'protected characteristics’. Protected characteristics are defined as follows:
   • age
   • gender
   • gender reassignment
   • ethnicity
   • disability
   • marriage and civil partnership
   • pregnancy and maternity
   • religion or belief
   • sexual orientation.
3. Foster good relations between people from different groups.

The equality duty is about integrating consideration of equality and good relations into day-to-day business. It means organisations need to look at how they can positively contribute to the advancement of equality and good relations. It requires these considerations to be reflected into the design of policies and the delivery of services, including internal policies, and for these to be kept under review. Within this report we reflect on the progress we are making.

The mainstreaming of equality, diversity and inclusion (EDI) through all our work is a priority for us. In 2018, we set up a programme board to oversee and monitor our progress in achieving this. During 2019, the board continued to:

• provide operational oversight of our work to make sure EDI is integrated into our core activities, as set out in our EDI roadmap
• agree measures and review performance against our annual EDI action plan, which sets out the activity that we are taking forward to support the Corporate Strategy 2017–20.

Our EDI work is linked to our staff values:

• Independent
• Professional
• Fair
• Inclusive
• Progressive

To help to describe our work to develop a fully inclusive culture and a diverse workforce, this report is structured in three sections. It builds on our report from 2018.

Organisation

As an organisation, we expect the law firms we regulate to create and champion an equal and diverse culture, so we need to make sure we do the same. We expect our staff to consider EDI throughout their work, whatever their role.

Labour market

Our offices are based in Birmingham and London and our workforce is broadly representative of the labour markets in these locations. There has been little change in the overall diversity profile of our staff over the last few years. We continue to work on areas where data suggests we have more to do to ensure diversity at every level in the organisation.

Roles at the SRA

Our staff grading is structured in the following way:

• A–D: non-management roles
• E–I: specialist and management roles
• J–L: heads of business units and directors. Leadership and senior management roles are included at this level.

All data is taken as of 31 December 2019. Please note, larger percentages have been moved to the nearest whole number while smaller percentages may show more detail. Where data reflects small numbers, we have not reported them in case individuals are identifiable. In some cases, the data in this report will be presented in line with the staffing structure to express key points.

From the start of a person's interaction and engagement with us, we believe it is important that we share our commitment to EDI. We want to encourage applicants to be individuals who are proud of their diversity, promoting equality of opportunity.

In 2019, we refreshed our preferred recruitment agencies, focusing on those with a commitment to EDI within their own organisations and in practice. These agencies were selected based on how they could support our key recruitment aims and diversity was a heavily weighted selection criterion.

Following a successful pilot, we renewed the Fair Hiring Project, an online learning platform designed to help candidates to develop skills, insight and confidence before they are assessed at interview. Its resource library covers more than 20 interview-related subjects.

Anyone who secures an interview, whatever the level and whether they apply internally or externally, can access learning materials if they are invited to interview. This platform reflects diverse perspectives and is accessible to all.

Diverse talent acquisition was a key focus for 2019. We commissioned and launched three new videos to explain what it means to be part of our operational teams. These feature our own staff and demonstrate the experiences of our diverse workforce. We also relaunched videos for our online careers page, where staff described why they were proud to work at the SRA. A key aspect of these was highlighting the importance we place on diversity and inclusion.

During 2019, we published the details of our family friendly policies. We also use the 'happy to talk' flexible working icon to show a job is suitable for flexible working and help attract external applications from a wider demographic.

We continue to monitor and measure our recruitment process at each stage by grade and by characteristic. We work closely with industry experts and have continued our commitment to high standards, signing up again to the Good Recruitment Campaign to share best practice and help with benchmarking data.

In October 2019, we hosted an external event for in-house recruitment professionals to hear from industry experts on diversity and inclusion strategies in recruitment and share best practice.

We continue to support our staff to make our commitment to EDI a reality. All our managers attend dedicated courses to equip them with the necessary skills to support their staff, and diversity and inclusion is at the heart of these initiatives.

We are keeping all our learning and development under review to make sure we continue to deliver effectively during the constraints brought by Covid-19.

In 2019, we launched a new Management Essentials programme, accredited by the Institute of Leadership and Management. This includes two sessions aimed at helping managers better understand our recruitment policy and best practice when it comes to unconscious bias and its effect on decision making.

The learning takes place away from the traditional classroom in an environment that simulates real-life situations. These use the work-life profile of a fictitious employee who, among other life events, has transitioned.

As part of this programme, all new managers attend a stress and wellbeing session where they practise how they could help and support team members who may be overwhelmed.

In 2019, we updated our Diversity and Inclusion eLearning and rolled it out to all staff. This interactive module immerses the learner in a fictitious corporate culture as a new team member and explore whether the team is acting in an inclusive and respectful way.

We have also introduced new eLearning modules on Trans and Making Reasonable Adjustments. These modules are mandatory for staff and assigned to all new starters. Staff must complete the modules at least every two years. Personal and professional development remains a key part of our learning and development offering, with funding available for external courses or qualifications (subject to key criteria set out within our professional development policy).

Our SRA Allies offer all staff the chance to show support to LGBTQ+ colleagues as part of their commitment to creating a diverse and inclusive workplace.

In December 2018, we expanded SRA Allies to give staff the opportunity to show support for all colleagues and invited those involved to make a pledge of support.

As an ally, staff can demonstrate this support by getting involved in key events and initiatives, which aim to create an environment where all staff are free from discrimination and able to be open about who they are. This helps to create a working environment in which staff can fulfil their potential, regardless of their gender, sexual orientation, disability, race or religion.

We know that if someone is an ally, they can help to challenge the negative behaviour that obstructs equality and inclusion. Allies act as a role model for our fair and inclusive values and actively support our staff networks.

In August 2019, as part of our ongoing commitment to building an inclusive and supportive culture, we held an SRA Allies event to further promote the scheme. Staff who have signed up were given badges to wear to further promote and display their commitment to a diverse and inclusive workplace. Our Board members have signed the ally pledge and shown open support for our aims of inclusivity and fairness.

In November 2019, we ran our staff engagement survey. We had an excellent response rate of 81%, up seven percentage points from the previous year, suggesting that staff wanted to engage with the organisation and speak up about improvements. The percentage of staff who believed that action would be taken because of the survey results also increased by 3% (compared to 2018).

It was positive to see the two biggest increases were about being better informed about mental health issues and that we do a good job of promoting the health and wellbeing of staff. This shows that initiatives introduced during 2019, such as the staff wellbeing calendar of events and the work of our mental health first aiders, has had an impact.

As with all our staff engagement surveys, we included bullying and discrimination questions. Discrimination has remained broadly the same as in 2018, and bullying has decreased by 3%.

We continue to have a zero-tolerance approach to bullying and discrimination. Throughout the year, we encourage reporting and provide support to staff and line managers to work towards a culture without any discrimination.

During 2019, we updated our Dignity at Work Policy to reflect gender identity and added case studies focusing on intersectionality. The revised policy was promoted as our corporate 'policy of the month' during July, emphasising the importance of maintaining a diverse and inclusive workplace

We were pleased to be recognised as a Top 100 Employer in the Stonewall Workplace Equality Index during 2019. This index assesses the progress employers are making on LGBTQ+ inclusivity.

This year, we raised awareness of trans and bi inclusion by holding several events and workshops. We also observed Pride History month in February and celebrated national LGBTQ+ days in the calendar, such as the International Day Against Homophobia, Transphobia and Biphobia and Transgender Day of Visibility.

We take LGBTQ+ inclusivity seriously and recognise the value of LGBTQ+ staff who bring with them different experiences and perspectives. We want everyone to feel comfortable being themselves at work, and in December 2019 we installed gender neutral toilets at our main offices.

Our networks, established and run by staff, continued to share ideas and collaborate on events and initiatives throughout 2019. They each have an internal intranet page to share messages and raise awareness.

Our current networks are:

• Black, Asian, and minority ethnic (BAME)
• iCare (carers)
• Christian
• Access Ability (disability)
• PridePlus (LGBTQ+)
• Network of Women
• Working Parents Network
• Mental Health First Aiders.

Some highlights from 2019

Our senior management team sponsor individual networks, taking a keen interest in and supporting the work of the network. We also have four Board members as network sponsors.

Our BAME network hosted and took part in well-attended events for Black History Month. This included more than 10 network members helping to facilitate speed networking sessions with external speakers. The network also ran sessions internally about intersectionality and about black women in the workplace.

The Access Ability network ran a programme of events, focusing on autism and hidden disabilities. They delivered presentations to staff about neurodiversity and autism in the workplace, promoting understanding, acceptance and inclusion of people with autism.

We continued to organise our popular staff faith events during 2019. These encourage staff from all religions and backgrounds to come together and celebrate as one. Events were held for Vaisakhi, Passover, Eid, Diwali and Christmas.

The Christian network introduced regular bible study sessions to learn the application of the bible and share points of view.

Our iCare network organised meditation workshops for staff and worked with our 2019 corporate charity, St Giles, to run a bereavement workshop. They also organised a lasting power of attorney presentation to explain the benefits and process to staff.

The Network of Women were at the forefront of raising awareness about the menopause and its impact at work. Members of the network were interviewed by senior policy makers at the Chartered Institute of Personnel and Development for research and case study material as part of their first menopause guidelines for employers, which have now been published.

The Network of Women also ran a successful series of international women's day events including panels on gender equality in the workplace and a talk about menopause in the workplace and the support available. Gender equality was also the focus of our internal radio programme 'Pulse' in March.

Our LGBTQ+ network was relaunched as PridePlus and held events to promote the network. This included a talk from Teacher Andrew Moffat about his inclusive education programme, No Outsiders, in the midst of the ongoing protests in Birmingham schools. Members of the network also supported our largest ever presence at Pride in Birmingham, London and Cardiff during 2019.

Our Mental Health First Aiders network ran several internal events, including a staff briefing for world suicide prevention day and a video for Men's Health Week, where colleagues shared their own experiences.

The Working Parents network was established and created a buddy scheme to support staff returning from maternity, paternity and shared parental leave.

We continue to provide a range of staff benefits which reflect our inclusive approach. In 2018, we introduced a digital platform, the Recognition Hub, to support timely recognition and reward for staff for embodying our behaviours and values.

During the summer of 2019, this was relaunched to add seven new ecards - one to celebrate each of our corporate behaviours. These are the behavioural competencies central to the work we do and form part of our recruitment and performance development review processes. We also introduced welcome and congratulations cards to recognise positive behaviour and enable us to congratulate all staff whatever their celebration or event.

We also made it easier for team thank you events to happen by making simple process changes to realise the opportunity to reward teams for their collective contributions. In a further development, we added information on pensions and our Employee Assistance Programme to the site, making it easier for staff to find more information on our benefits in one place.

To celebrate the relaunch staff received a modest monetary award to be used through the system.

We will continue to further evolve our reward and recognition platform. This is in line with our 2018 Staff Survey Corporate Action Plan where we introduced an objective to enhance reward and recognition to make it more visible, individual and create an uplift in positivity about our recognition portfolio.

The 2019 staff survey saw an increase of 6% in response to the question: 'I believe the Recognition Hub and its initiatives are a good way to recognise the achievements of colleagues.'

Key highlights and trends

Our gender split is 62% female (412 people) and 38% male (251). This is compared to 59% female (359) and 41% male (249) in 2018.

Of those promoted in 2019, 61% (40 people) were female and 39% (26 people) were male. This compares to 55% (33) of promotions achieved by females and 45% (27) of promotions achieved by men in 2018.

Flexible working is an area that continues to show a significant gender split. We encourage and support colleagues to work flexibly and the number of requests we received increased from 67 in 2018 to 86 in 2019.

Seventy-nine per cent (68) of these applications were submitted by females, up nine percentage points from 2018. There has been a slight decrease in the number of flexible working requests made by males, from 20 in 2018 to 18 in 2019.

In 2019, we asked staff to review and update their personal diversity data held on our HR system. We added two new questions regarding gender identity and gender reassignment. Adding these questions will help us to check that we are being fair and that all staff are represented, supported and included. Around half of all staff members provided answers to the new questions.

In February 2020 we published the Gender Pay Gap figures for Law Society Group 2019. The figures compare positively with the national gender pay gap, which is 17.3% (ONS 2019).

The mean pay gap is the difference between hourly earnings for women and men, taking the sum of all hourly rates divided by the total number of women or men in the sample.

The median pay gap is the difference between the midpoints in the ranges of hourly earnings between men and women. It takes all salaries in the sample, lines them up in order from lowest to highest, and picks the middle-most salary. The figures reflect the female/male profile across the organisation, and the presence of more men in the senior management teams. In addition, a higher proportion of females work part-time in lower level roles.

In 2018, the performance-based bonus scheme was ended for most roles and instead staff received a one-off flat rate bonus. This contributed to an improvement in the bonus gap. In addition, through our Recognition Hub, staff can send and receive a range of recognition cards, receive thank you and end of year awards, and access discounts and cashback on spend.

We are committed to reducing the gender pay gap and have an action plan in place.

This includes:

• an ongoing review of our reward strategy and how we recognise staff
• continuing to review how we recruit, retain and promote females into senior roles
• reviewing our policies, processes and practices to provide an environment where everyone can flourish.

Key highlights and trends

The largest proportion of our staff (30%) are within the 35-44 age bracket, followed by those in the 25-34 age bracket (27%). In 2019, both age brackets saw a decrease compared to 2018. While those aged 16-24, 55-64 and 65+ saw a percentage increase in 2019.

All age brackets were represented across all pay grades except for 16-24 year olds and over 65s. Within grades J-L, there was no representation from within these two age brackets. This has not changed since 2016.

We promoted 66 colleagues during 2019. Twenty-nine per cent were staff aged 25-34, down from 48% in 2018. Promotions for those in the 45-54 age group increased from 13% to 21% in 2019. Six staff in the 55-64 age group were promoted in 2019, up 7% from the year before.

In 2019, 23% of external candidates applying to the SRA were in the 16-24 age bracket. This compared to 21% in 2018. This suggests that we continue to be attractive to external candidates within this younger age group.

Key highlights and trends

The term BAME includes any member of staff who self-identifies their ethnicity as other than white British.

Our overall workforce profile reflects that of the local labour markets in Birmingham and London. Forty-two per cent of new starters were BAME, an increase of four percentage points from 2018.

Asian/Asian British are still our largest ethnic minority group, making up 20% (131 of our workforce), up three percentage points since 2018. However, the proportion of BAME staff continues to be lower in the middle and senior management grades than in the less senior grades. This is the case with many organisations and is an area where we want to see improvement.

Of those promoted in 2019, 34% were BAME (compared to 27% in 2018). BAME employees made up 46% of internal applications, the same proportion as the previous year. In 2019, 40% (31 people) of successful internal applicants were BAME. This is up significantly from 28% in 2018.

We welcome the progress but know we have more to do. We will build on our work to date to make sure our people have every opportunity to develop their careers within the SRA.

BAME candidates made 34% of external applications for grade J-L roles in 2019 and none of these applicants were successful in securing a role at this level. In 2018, one BAME person was recruited externally into these grades and, as then, the number of roles available at grades J-L was very low (15 roles). This will be an area of sharp focus for us in future.

Overall, we have seen some welcome improvements in our ethnic diversity. But the picture is less positive at senior level and we are committed to doing everything we can to make our senior grades more reflective of our wider workforce.

Key highlights and trends

In 2019, 7% of our workforce (46 people) have declared that they have a disability. This is up from 6% in 2018.

Fourteen per cent (nine people) of promotions went to staff who declared a disability. This compares to 7% (four people) in 2018.

Although the numbers are small, the proportion of individuals applying who declare a disability is steady. In 2019 it was 4% of external applicants, compared to 3% in both 2018 and 2017. We also saw that 4% (five people) of new starters in 2019 had a disability, which is an uplift from 3% in 2018, although the numbers are, again, very small.

Key highlights and trends

Within our workforce, the majority of staff identified as being Christian (242 people). The second largest group are those saying they have no religion (225 people), which has gone up by three percentage points since 2018.

Of other groups, 8% (52 people) identified as Sikh, 7% (45 people) as Muslim and 3% (18 people) as Hindu. All increased by one percentage point from the previous year.

Of staff working in grade E-I roles, 39% (194 people) identified as Christian, 33% (163 people) said they had no religion, 9% (43 people) identified as Sikh and 4% (22 people) identified as Muslim.

For staff working in grade A-D roles, 29.9% (35 people) identified as Christian, 26.5% (31 people) said they had no religion and 18.8% (22 people) identified as Muslim.

Most people who have no religion (58%) work as directors or heads of business units (grades J–L). There were also 25% (13 people) who identified as Christian, 2% (one person) who identified as Buddhist and 2% (one person) who identified as Muslim working in these senior roles.

In 2019, 16% (10 people) of those who received a promotion identified as Buddhist, Muslim or Sikh.

Key highlights

Our diversity data shows that 2% of our staff (15 people) disclosed their sexual orientation as gay/ lesbian or bisexual. While 10% (63 people) chose not to specify their sexual orientation. We have seen a slight improvement of 1% of staff disclosing their sexuality compared to last year.

During 2019, 3% (four people) of new starters declared that they were gay/lesbian or bisexual. While 3% of external applicants in 2019 declared that they were gay/ lesbian or bisexual.

No one in grades A-D and J-L disclosed that they were gay or lesbian. Bisexual members of staff were represented across all grades.

Leadership

We will enhance our senior management team (SMT) role in role modelling inclusive leadership behaviours and leading our EDI work to ensure equality of opportunity. As part of that we will use an employee 'lifecycle' approach to support our SMT as we focus resources to make a positive impact on EDI.

Using the employee lifecycle, we can improve how we develop and recognise talent, monitoring and analysing data by diversity characteristics so that we can better understand what is happening and what more we need to do.

Resourcing

We will continue to review and update diversity content in recruitment marketing materials and available online platforms, as well as any relevant training content. We will also analyse recruitment data to identify trends and make positive changes.

In addition, we will be looking at where the barriers to entry may be, including key areas such as external applicants for senior roles broken down by ethnicity and at what point BAME candidates exit the recruitment process, compared to white external candidates.

We will take a similar approach to understanding what is happening in our internal recruitment processes. Throughout our work, we will adapt our processes to the new ways of working caused by the Covid-19 pandemic and support people to engage with us in these unusual circumstances.

Learning and development

We will review our EDI eLearning to make sure staff understand gender identity, transgender and our approach to trans inclusion in the workplace. This will include case studies to distinguish between sexual orientation and transgender. Our induction programme will be reviewed to focus on diversity and inclusion and new starters will be given information about our staff networks. And we will support these new colleagues in the remote working environment we are all operating within at the moment.

We will promote internal training modules such as 'Managing your career' through our staff networks to encourage staff from all demographics to attend.

Other initiatives

We will continue to review our progress against our staff survey and action plans, including those areas relating to EDI, effective leadership and managing change.

We will continue with our membership as a Disability Confident level two employer and build on this to work towards achieving level three accreditation and becoming a Disability Confident Leader. This will involve further training for line managers, some of which can be incorporated into the recruitment and selection training.

We are working closely with Stonewall on developing our next application for the top 100 Employers in their annual Workplace Equality Index.

Our focus for 2020 will be on intersectionality and encouraging our staff networks to work even more closely together against the backdrop of the Covid-19 pandemic. Our plans include to recruit intersectional role models and introduce a process to allow non-binary people to identify in more than one way, for example, providing multiple security passes to reflect different gender identities.

We will build on our experience over recent years and particularly during the Covid-19 pandemic to introduce more agile working by implementing a greater degree of home working for all staff and increasing the scope for flexible working hours.

Reward

The findings within our second Gender Pay Gap report will allow us to engage with staff to make progress in this area and we will seek to make flexible working more accessible.

We will use the Recognition Hub more widely to celebrate and communicate success with others. We will promote a greater level of peer to peer nomination and recognition and encourage nominations that recognise achievement in line with our behaviours and values.

Networks

We will build on network sponsorship work to date to increase visibility of our SMT and the wider leadership team in actively endorsing and promoting each of the networks. This will help to embed and strengthen their position within the SRA and encourage further diversity and new ideas. In turn, we believe this will have a positive impact on attraction and retention of those with a protected characteristic. Some next steps for our staff networks include:

Recruit and train six new mental health first aiders.

iCare will run a virtual event for international persons with disability day.

Network of Women will promote 'each for equal' as part of International Women's day.

All our staff networks will work together to provide useful information, videos and online intranet content to support all staff during the Covid-1 9 pandemic. Themes will include mental health, physical health, relaxation, and meditation.

Continue to endorse and promote our staff networks further to embed and strengthen their position within the SRA.