PAS 1948:2023

Diversity, equity and inclusion

in the workplace – Code of practice
Publishing and copyright information
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last issued.
© The British Standards Institution 2023.
Published by BSI Standards Limited 2023.
ISBN 978 0 539 02459 3
ICS 03.100.30 Management of human resources
03.100.01 Company organization and management in general

No copying without BSI permission except as permitted by copyright law.

Publication history
First published June 2023
 PAS 1948:2023

Contents
Foreword........................................................................................................... ii
Introduction....................................................................................................... iv

1 Scope............................................................................................................... 1
2 Normative references.................................................................................... 3
3 Terms and definitions.................................................................................... 4
4 Implementing an effective strategy and framework for supporting
diversity, equity and inclusion across single and multi-jurisdictional
workplaces..................................................................................................... 9
5 Policies, processes and practices for promoting and supporting diversity,
equity and inclusion in the workplace......................................................... 16
6 Assessing the impact of diversity, equity and inclusion on organizational
performance................................................................................................... 31
7 Engaging and supporting underrepresented groups ................................. 33
8 Implementing the concept of “diversity of thought” and “intercultural
competence”.................................................................................................. 35
9 Measuring progress and developing a strategy for continuous
improvement.................................................................................................. 37

Annexes
Annex A (informative) Self-assessment and strategy..................................... 38
Annex B (informative) Workplace toolkit........................................................ 43
Annex C (informative) Role play and interactive exercises............................ 49
Annex D (informative) Sample stakeholder surveys....................................... 50
Annex E (informative) Glossary........................................................................ 55

Bibliography...................................................................................................... 56

List of figures
Figure 1 – Simple five step approach [© All-in Diversity Project (2021)]....... iv
Figure 2 – Policy to performance..................................................................... 16
Figure 3 – The recruitment cycle...................................................................... 22

List of tables
Table A.1 – Self-assessment questionnaire...................................................... 38
Table A.2 – Example of a simple five step plan............................................... 42
Table B.1 – Action plan template..................................................................... 43

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PAS 1948:2023

Foreword
This PAS was sponsored by All In Diversity. Its development was facilitated by
BSI Standards Limited and it was published under licence from The British
Standards Institution. It came into effect on 30th June 2023.
Acknowledgement is given to Christina Thakor-Rankin, The PAS process enables a standard to be rapidly
as the technical author, and the following organizations developed in order to fulfil an immediate stakeholder
that were involved in the development of this PAS as need. A PAS can be considered for further development
members of the Steering Group: as a British Standard, or constitute part of the UK
• Abounding Solutions input into the development of a European or
international standard.
• All-in Diversity Project
• Allwyn
Use of this document
• Creative Treaty
• Diversio As a code of practice, this PAS takes the form of
recommendations and guidance. It is not to be quoted
• Diversity Trust
as if it were a specification. Users are expected to
• Fair Play Talks ensure that claims of compliance are not misleading.
• Foster Diversity
• Inclusion Included Users may substitute any of the recommendations in
this PAS with practices of equivalent or better outcome.
• Innovate UK
Any user claiming compliance with this PAS is expected
• Light & Wonder to be able to justify any course of action that deviates
• Oxford University Press from its recommendations. This publication can be
• Skills 4 UK withdrawn, revised, partially superseded or superseded.
Information regarding the status of this publication can
• Sytner Group
be found in the Standards Catalogue on the BSI website
• The Certification Group at bsigroup.com/standards, or by contacting the
• Women on Boards Customer Services team.

The British Standards Institution retains ownership and Where websites and webpages have been cited, they
copyright of this PAS. BSI Standards Limited, as the are provided for ease of reference and are correct at
publisher of the PAS, reserves the right to withdraw or the time of publication. The location of a webpage or
amend this PAS on receipt of authoritative advice that website, or its contents, cannot be guaranteed.
it is appropriate to do so. This PAS will be reviewed at
intervals not exceeding two years. As a code of practice, this PAS takes the form of
recommendations and guidance. It is not to be quoted
This PAS is not to be regarded as a British Standard. It as if it were a specification. Users are expected to
will be withdrawn in the event it is superseded by a ensure that claims of compliance are not misleading.
British Standard.
Users may substitute any of the recommendations in
this PAS with practices of equivalent or better outcome.
Any user claiming compliance with this PAS is expected
to be able to justify any course of action that deviates
from its recommendations.

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 PAS 1948:2023

Presentational conventions
The provisions of this document are presented in
roman (i.e. upright) type. Its recommendations are
expressed in sentences in which the principal auxiliary
verb is “should”.

Commentary, explanation and general informative

material is presented in smaller italic type, and does not
constitute a normative element.

Where words have alternative spellings, the preferred

spelling of the Shorter Oxford English Dictionary is used
(e.g. “organization” rather than “organisation”).

Contractual and legal considerations

This publication has been prepared in good faith,
however no representation, warranty, assurance or
undertaking (express or implied) is or will be made, and
no responsibility or liability is or will be accepted by
BSI in relation to the adequacy, accuracy, completeness
or reasonableness of this publication. All and any such
responsibility and liability is expressly disclaimed to the
full extent permitted by the law.

This publication is provided as is, and is to be used at

the recipient’s own risk.

The recipient is advised to consider seeking professional

guidance with respect to its use of this publication.

This publication is not intended to constitute a contract.

Users are responsible for its correct application.

Compliance with a PAS cannot confer immunity from

legal obligations.

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PAS 1948:2023

Introduction
This PAS provides practical guidance and a number of
workplace tools (Annex A, Annex B, Annex C, Annex D
and Annex E) for organizations seeking to develop and
implement a framework and culture that encourages,
promotes, and supports diversity, equity and inclusion
in the workplace.

The PAS aims to break down a topic that some might

see as a complicated or costly concept into five
simple steps, shown in Figure 1, that are clear, easy to
understand and translate into action.

Figure 1 – Simple five step approach [© All-in Diversity Project (2021)]

This PAS is applicable to, and can be used by any In recent years, academic and vocational research and
organization of any size, in any sector, anywhere in data-driven analysis of organizational practices from
the world. world-leading institutions has established a clear link
showing the growing importance between diversity,
The standard is not based upon and does not include equity and inclusion and organizational and commercial
any reference to any specific laws or regulations. performance.
Organizations are responsible for checking that any
practices they choose to adopt or implement, are
compatible with the laws and regulations of the
locations and environment(s) in which they operate
or are based.

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The World Economic Forum publication The Case for Research undertaken in the McKinsley publication
Diversity, Equity and Inclusion 4.0 [1] cites three key Delivering Through Diversity [3] tracked over a 5-year
reasons why diversity, equity and inclusion is a greater period and updated in their more recent report
imperative than ever before for any business. Diversity Wins: How inclusion matters [4]. This identifies
a) Moral imperative: Giving equal access and a statistically significant correlation between diverse
opportunities to all people to work under fair and workforces and the ability to out-perform competitors
equitable conditions is simply the right thing to do. and increase profitability.
b) Legal imperative: The International Labour
The recent McKinsley report [4] indicates that
Organization has put into action a range of
“Companies in the top-quartile by gender diversity
conventions to eliminate discrimination from all
were now 25% more likely to outperform financially,
aspects of work.
whilst top-quartile companies with greater ethnic
c) Economic imperative: To reap the full competitive diversity were 36% more likely to outperform on
advantages of diversity, equity and inclusion, some profitability”.
initial learning effort by managers, employees and
the whole organization might be required – but Whilst the research based upon commercial metrics and
a wide range of research conclusively documents profitability might not be applicable to non-commercial
that well managed diverse teams significantly organizations, the need to make effective and impactful
outperform well-managed homogenous ones decisions applies to all organizations.
over time.
This is especially true for those organizations either
The business case for diversity has also been researched developing or dependent upon emerging technologies.
and evaluated by a number of established authorities.
In 2021, Forbes published an article [5] exploring the
The Gartner CIO Executive Communication Guide [2] relationship between artificial intelligence (AI) and
concluded that “75% of organizations with frontline diversity, commenting that “AI systems are built on
decision-making teams that reflect a diverse and learning from data, and if the data is skewed as per
inclusive culture will exceed their financial targets. the view of the person building it, it can have major
The impact of diversity, equity and inclusion is consequences. Furthermore, AI is already around us
highly positive. Gender-diverse and inclusive teams in places you might not be aware of. For instance, the
outperformed gender-homogeneous, less inclusive surveillance cameras in many countries already have
teams by 50%”. sophisticated AI technology that evaluates every second
of the movement of the citizens. If there is implicit bias
The report states that “the difference in employee in the system, it can be unjust to some people. Diversity
performance between nondiverse and diverse holds great importance because we want to make sure
organizations is 12%” and the application of cognitive that when an AI system makes a call, it will be able to
diversity “can be what saves the team from ‘groupthink’ make accurate decisions.”
and allows them to achieve better outcomes”.
NOTE 1 ”Groupthink” is a phenomenon where the However, a 2019 study by the AI Now Institute entitled
desire for harmony or conformity results in irrational, Discriminating Systems [6] shared that women make up
dysfunctional, or poor-quality decision-making. This only 15% of AI researchers at Facebook and just 10%
stems from the desire to minimize conflict and reach at Google. The study also found that less than 5% of
a consensus by actively discouraging challenges, the staff at Facebook, Google and Microsoft are black,
dissenting viewpoints or allowing any influences or while black workers in the U.S. as a whole represent
views from outside of the immediate group. This results roughly 12% of the workforce. Due to the lack of
in decisions being made without any critical evaluation diverse engineers and researchers, the products that
of the alternatives. are developed and used by billions of users can result in
the propagation of bias on a large scale. Consequently,
inclusion and diversity in AI are crucial.
NOTE 2 While the impact of gender and race bias in
business is now well established, recent research is
now helping to raise awareness of the impact of bias
towards other under-represented groups.

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NOTE 3 Research from Purple1) states that, “The • emphasize the relationship between diversity and
spending power of disabled people and their commercial and non-commercial performance; and
household worldwide is currently estimated to be • help organizations develop a framework for
worth $8 trillion, increasing by 14% per annum. Only promoting and supporting diversity, equality and
10% of businesses have a targeted strategy for this inclusion in the workplace through standards such
huge market”. It was indicated that “more than as this PAS.
4 million people in the UK abandoned a retail website
because of the barriers they found, taking with them Diversity, equity and inclusion are complex concepts.
an estimated spend of £11.75 billion. In 2019, that lost Our interpretation of these concepts is influenced by
business, the ‘Click-Away Pound’, has grown to who we are and where we come from. Our perceptions
£17.1 billion”. With the advent of Web 3.0 and an even and attitudes, including those about other people, are
greater shift towards technology as enabler and it is often based on a combination of our cultural, social,
vital that organizations understand the impact of bias educational, religious and environmental backgrounds.
at even stage of the development to delivery lifecycle.
The established views and attitudes of the individuals
The business and organizational case for diversity, in an organization, or the attitudes of individuals
equity and inclusion has been established against a leading an organization can often become the culture
background of statistical data analysis, performance for that organization. This can be the views of leaders,
measures and metrics. This PAS is designed to enable managers, key decision makers or others with influence
organizations to develop policy and practices that help within the organization.
them to:
• engage with and educate organizations on the Some organizations might be based in jurisdictions
benefits of diversity, equality/equity and inclusion; where laws and regulations or religious beliefs, customs
• emphasize the increasing importance of social or practice could have a direct impact on their approach
responsibility, sustainability (Environmental and Social to diversity, equity and inclusion in the workplace.
Governance), ethical practices and “doing the right
Some organizations such as front-line emergency
thing” to investors, employees, and customers;
services, might insist on certain physical requirements as
• benchmark levels of diversity, equality/equity and a pre-requisite for particular posts.
inclusion across organizations and industries;
• highlight the importance of diversity, equality/equity In such cases, organizations should clearly communicate
and inclusion on innovation, technology and product the reason and rationale for their position, including any
development; legal, regulatory, health and safety, cultural, religious or
• understand the impact of flexible, virtual and remote other factors that the decision is based upon.
working practices on employee demographics, NOTE 4 This does not prevent the organization from
perception and sense of belonging; considering adjustments to the requirements of the
• consider how organizations can build diversity, equity role, the environment, or through use of equipment or
and inclusion into existing procurement processes and technology, to make it more accessible to a wider group
supply chains; of individuals. A rationale might be a minimum level of
physical ability or mobility in order to fulfil a necessary
• identify and develop diversity, equality and inclusion
aspect of the role, such as lifting physical objects.
strategies for different categories of stakeholder,
from investors and shareholders, to employees,
customers, suppliers and providers;
• expanding perceptions and definitions of talent and
ensuring they are reflected in leadership positions
and roles;

1)
Available at: https://wearepurple.org.uk/business/

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Some organizations might be located in geographical When agreeing actions, organizations can benefit from
areas which have varying levels of representation from considering the activities that might be pre-requisites
different cultural and social groups. for achieving a specific goal or objective.
NOTE 5 For example, it is not uncommon for capital NOTE 6 For example, if the goal is to collect data on
cities or urban areas located close to national borders levels of diversity, the organization needs to decide
to have a greater level of representation from a wider what data they want to collect and how it is collected,
range of different cultural or social groups compared and how it is communicated across the organization,
to smaller towns in more provincial areas. In such including what they are doing, why they are doing it
cases organizations might seek to have a workforce and how.
that is as representative of the local population as
possible in terms of gender, all faiths or none, ethnicity,
abilities or any other characteristic or trait. Where
employees are required to be based at a specific
location(s), organizations can also consider factors
such as commute time and cost, including access and
availability of public transport. Where employees are
not required to be based at a specific location, remote
or flexible working could allow organizations to have
employees from a much wider geographical area and
increase levels of representation from different groups
and backgrounds.

Changing workplace culture can be disruptive and have

a negative impact on an organization if it is not done in
a thoughtful and structured way.

While this PAS gives recommendations and guidance

on policies, practices, and approaches, organizations
can select and implement the recommendations and
guidance which is most appropriate to them and at
their own pace and budget.

The recommendations do not have to be implemented

in any particular order, but a phased approach that
allows the organization to measure progress and
results against its aims and objectives is often the
most successful.

Organizations can start with the recommendations

that are likely to deliver change quickly and with
minimal disruption to the organization. This could be
setting up a Diversity Board or Committee or having
a set of HR and people management policies that
help support diversity, equity and inclusion. They can
then work towards developing a clear plan of action
with a defined timetable for implementing other
recommendations and changes to working practices.

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1 Scope

This PAS gives recommendations for practical steps h) recognizing, engaging and supporting
that organizations can take to help them develop and underrepresented social and cultural groups;
implement an effective framework to support diversity, i) creating inclusive brands, customer engagement
equity and inclusion in their workplace(s). The PAS and workplace culture, through adapting change
shows organizations how to develop and implement management strategies for diversity, equity
policies and practices to support their diversity, equity and inclusion;
and inclusion aims and objectives in keeping with their
j) understanding and implementing concepts such as
existing principles and framework.
“diversity of thought”, “dimensions of diversity”,
“intercultural competence” and “cognitive diversity”;
It is intended to be used as a practical implementation
guide for other framework standards, such as k) incorporating the principles of “inclusive
BS ISO 30415, BS 76000:2015 and BS ISO 45003:2021. innovation” and “inclusive by design” into services,
business models, business processes, technology and
This PAS includes recommendations and guidance as product development cycle;
well as standards and principles statements issued by l) setting achievable targets and objectives with
diversity, equity and inclusion organizations, research clear Key Performance Indicators (KPIs) and data
institutes, government agencies, and other bodies. analytics to support continuous improvement; and
m) measuring the progress of the organization in
It covers practical measures for: creating and maintaining an effective culture of
a) demonstrating leadership buy-in and commitment diversity, equity and inclusion.
to diversity, equity and inclusion at all levels of NOTE 1 While this is a comprehensive list it is not
the organization; a definitive one; organizations can add measures
b) incorporating diversity, equity and inclusion and actions as applicable to their evolving aims
principles and objectives into an organization’s and objectives.
internal policies, practices, processes and procedures;
c) establishing the organizational and business It is applicable to any organization of any size,
benefits of creating and maintaining an effective description, sector, industry or location.
culture of diversity, equity and inclusion;
It can be applied across all aspects of an organization’s
d) recruitment and retention strategies that enhance
operations including but not limited to:
diversity, equity and inclusion;
1) board governance;
e) addressing behaviour which is inconsistent with
diversity, equity and inclusion principles through 2) internal and external stakeholder engagement;
education, understanding and awareness, and 3) human resources and people management;
supporting people who challenge such behaviour; 4) communications, marketing and branding;
f) identifying appropriate diversity, equity and 5) technology (including new and emerging
inclusion learning and development needs at all technologies); and
levels within an organization;
6) design and development of products and services.
g) enabling peer networks to support
underrepresented social and cultural groups;

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It is intended for use by decision-makers and influencers

including, but not limited to:
i) board members and organizational leaders;
ii) operational and management teams;
iii) HR and people professionals;
iv) trade union and employee association
representatives;
v) advisors, auditors and investors; and
vi) any individual within the organization looking
to promote diversity, equity and inclusion.

This PAS does not cover existing local, national, or

international employment law, regulation or policy.
NOTE 2 It might not be appropriate or legal for an
organization to implement one consistent policy across
all of its operations due to local laws and regulations,
religion or local custom, culture and value and beliefs.
For example, it might be possible to apply policy and
practice to gender equality, sexual orientation or same
sex/gender relationships in some locations but not
in others.

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2 Normative references

There are no normative references in this document.2)

2)
Documents that are referred to solely in an informative manner are listed in the Bibliography.

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3 Terms and definitions

For the purposes of this document, the following terms 3.5 cultural groups
and definitions apply.
group(s) of people connected or related by one or
more common or shared physiological or psychological
3.1 audit trait, characteristic, geography, behaviour, belief, idea,
systematic, independent, documented process for custom, attitude, value
obtaining documented information, statements of NOTE 1 Common cultural groups include, but are not
fact or other relevant information and assessing them limited to:
objectively to determine the extent to which the audit • gender;
criteria are fulfilled
• race;
NOTE An audit can be an internal audit (first party)
• religion;
or an external audit (second party or third party),
and it can be a combined audit (combining two or • ethnicity;
more disciplines). • parental status;
• sexual orientation;
[SOURCE: BS 76000:2015, 3.1]
• age or generation;
• visible or invisible conditions – including physical,
3.2 belonging neurological, mental or other atypical experience; and
sense, knowledge or feeling of fitting in and being • any trait or characteristic that allows an individual or
accepted unconditionally in a way that creates a group to identify themselves as an underrepresented
feeling of being safe, valued, with a sense of place group compared to other cultural or social groups.
and purpose, allowing individuals to participate in the
NOTE 2 Individuals can identify with more than
same way as others without any conscious awareness
one cultural or social group at any given time.
of being different
This might lead to experiences that are different to
those experienced by the majority in a cultural or
3.3 bullying social grouping.
conduct or behaviour intended to cause fear, humiliation, NOTE 3 The terms race and ethnicity are often
embarrassment or loss of dignity or to intimidate, coerce, confused. The term race is most commonly used to
or apply emotional or physical pressure as a means of describe a group of individuals sharing similar physical
wielding or showing power over another and biological traits and/or characteristics, whereas
“ethnicity” refers to broader cultural expression
NOTE 1 Bullying is not punishable by law. See also
and identification.
“harassment” (3.13).
NOTE 2 A bully is someone who engages in bullying
behaviour. 3.6 discrimination
NOTE 3 Bullying behaviour can also be linked to or treating an individual or a group of individuals in a way
be similar to harassment but is not the same. that puts them at a disadvantage or at an advantage
compared to others
3.4 cognitive diversity NOTE 1 Some local laws and regulations permit the
treatment of individuals and groups to be different
mix of different intellectual styles, methods or based on their characteristics (“protected group”,
approaches to processing information and solving see 3.22) as a means of overcoming past or current
problems that can result in different and unique disadvantages. This practice is known as “positive
perspectives, conclusions or outcomes action” or “affirmative’ action” and seeks to overcome
NOTE Cognitive diversity is also linked to “diversity disadvantages experienced by certain groups, and
of thought” (3.8) and innovation. address the under-representation of those groups
by actively seeking to appoint candidates from
under-represented groups. This is not to be confused

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with the term “positive discrimination” which is a NOTE 2 Social or cultural groups might be identified
deliberate and intentional action designed to exclude based upon one or a combination of characteristics or
or treat someone in a manner that would result in a traits such as gender, race, ethnicity, sexual orientation,
disadvantage to them compared to others. condition, age, religion, socio-economic background,
NOTE 2 Organizations might use “‘positive or education, geography, neurology, physiology.
affirmative action” (also referred to as “positive NOTE 3 Bringing together a number of different
discrimination” or “local content” dependent upon experiences, perspectives and insights results in
where it is used in the world), sometimes in association different ways of looking at something which can lead
with quota-based systems to increase the number of to new ideas, initiatives and innovation.
employees from underrepresented or specific groups
where this is allowed or permitted by appropriate local 3.9 documented information
laws and regulations. Positive or affirmative action
is most often used in relation to “protected groups” information required to be controlled and maintained
where social or cultural traits and characteristics can be by an organization and the medium on which it is
applied in addition to skills, experience and ability to contained
meet the requirements of a role. NOTE 1 Documented information can be in any format
NOTE 3 Characteristics associated with “protected and media and from any source, subject to applicable
groups”, such as age, gender, race, and so forth can be data management and data protection laws
specific to, and vary across different jurisdictions. and regulations.
NOTE 4 Treating all individuals in the same way NOTE 2 Documented information can refer to:
(equally) is not the same as treating all individuals • the management system, including related processes;
fairly (equitably), as applying the same practices to • information created in order for the organization to
all, irrespective of differences may result in some operate (documentation); and
individuals being placed at a disadvantage. For
• evidence of results achieved (records).
example, offering a bonus to all employees which in
reality may only be attainable by some would give
some an unfair advantage over others. 3.10 equality
state where everyone is granted the same rights and
3.7 diversity responsibilities, where everyone has been offered the
same opportunities and has been treated without
state not dominated by any one social or cultural group
regard to their own individual or group needs
but which also includes representatives from a number
of different social and cultural groups
NOTE 1 A diverse organization (reflective of both 3.11 equity
internal and external stakeholders) includes factors that system of justice and fairness designed to give everyone
influence the identities and perspectives that people the same opportunities by acknowledging and making
bring when interacting at work. allowances for differences that would otherwise place
NOTE 2 A diverse organization (reflective of both them at a disadvantage compared to others
internal and external stakeholders) can foster learning NOTE 1 For example if a role required individuals to
from others who are not the same, about dignity, access stock on a high shelf, the organization needs to
respect and inclusiveness for everyone, and about make allowance for the individual differences in height
creating workplace environments and practices that by providing steps or ladders to give equal accessibility
foster learning from others to gain advantages of to all.
diverse perspectives. NOTE 2 Equity demands fairness in every situation.
Individuals are treated fairly but differently as their
3.8 diversity of thought circumstances are given weight. It aims to provide all
the individuals with an equal opportunity, to let them
where individuals in a group think, behave and process
attain their maximum potential. Equity makes sure
information differently from each other, allowing them
that all the individuals are provided with the specific
to bring a range of different perspectives and opinions
resources they need (not just the same resources as
to an idea, problem or discussion often due to their
everyone else) to have access to the same opportunities.
different social or culture backgrounds
NOTE 1 See also “cognitive diversity” (3.4).

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NOTE 3 An example of equity might be allowing an NOTE 1 Inclusion (also known as inclusivity) is more
individual with dyslexia more time for a written test or than just including individuals from different groups; it
providing them with a verbal version of the test. is being made to feel welcome and accepted as having
NOTE 4 Not all situations can support equity. For worth and value. See “belonging” (3.2).
example, a role which requires an individual to engage NOTE 2 Commitment to the valuing and inclusion of
in physical activity such as running or climbing a all the ways people are different requires a transparent
ladder, such as a firefighter, is by its very nature limited approach that goes beyond legal compliance and
to those who are able to meet a set of minimum embeds and sustains wider cultural change, and
requirements relating to physical ability, and to make demonstrates that everybody is welcome, valued and
changes would introduce unacceptable risk to others. respected, feels safe and without fear of being judged
An organization is expected to apply appropriate within the team and the wider organization.
judgment in determining whether to
apply the concept of equality or equity in any 3.15 intercultural competence
specific situation.
ability to understand how something is interpreted,
viewed or perceived by a different cultural or social
3.12 flexible and remote working group and adapting communication and behaviour
adjustment to established working practices and based upon that understanding
patterns, including changes made to how, when and
where a person undertakes the duties of their role 3.16 intersectionality
NOTE 1 Flexible working is as much about the
combination of one or more cultural or social characteristics
individual as it is the requirement of the role, such
or traits that form part of a person’s identity
as some individuals preferring to work remotely or
from home, whereas others might prefer an office NOTE 1 People can identify with more than one
environment due to their personal circumstances of characteristic, or social grouping, and might have
living arrangements not easily supporting working intersecting identities. This can lead to experiences that
from home. are different to those experienced by the majority of
a social grouping. For example, two environmentalists
NOTE 2 This includes changes to the time, location and
might identify with an environmental social group, but
working arrangements to support the needs of the
each identify with a different cultural group.
individual. For example, allowing parents flexible start
or finish times to be able to work around school NOTE 2 A failure to recognize and understand
drop-off/pick‑up times, or child-care arrangements. intersectionality can result in an organization identifying
individuals by just one characteristic with the result that
NOTE 3 Flexible working can also be referred to
some challenges, issues or inequalities remain hidden.
as “smart working” or “agile working”. Where
For example, if an individual is identified only by gender
organizations choose to use these newer terms, a
or ethnicity and not the fact that gender and ethnicity
distinction needs to be drawn between “smart or
combined is a challenge in its own right.
agile working” as a reference to flexible working,
and not as applied to the use of technologies, project NOTE 3 The theory of “intersectionality” was first publicly
management and efficiency driven work process. laid out by Kimberlé Williams Crenshaw in 1989 in a paper
titled Demarginalizing the Intersection of Race and Sex:
A Black Feminist Critique of Anti-discrimination Doctrine,
3.13 harassment Feminist Theory and Antiracist Politics, published in the
conduct or behaviour that is unwanted, uninvited, University of Chicago Legal Forum [7].
unsolicited, or perceived by the recipient, to cause
annoyance, offense, insult, fear, humiliation, 3.17 mentoring
embarrassment, discomfort, distress or loss of dignity
act or process of transferring knowledge, supporting
NOTE The key difference between bullying and
learning and development, or providing help and
harassment is that harassment is linked to discrimination
advice to another in order to enhance their skills,
and is punishable by law. Bullying is not punishable by law.
experience as part of their on-going development and
ability to access new opportunities
3.14 inclusion NOTE See “reverse mentoring” (3.25).
allowing or inviting participation for all irrespective
of differences

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3.18 micro-aggression 3.23 psychosocial

statement, action or incident regarded as an instance combined influence of psychological factors and
of indirect, subtle, or unintentional bias, prejudice, surrounding social environment on an individual’s
or discrimination against an individual from a physical and mental wellness and their ability
marginalized or under-represented group, such as an to function
off-hand comment or remark, a joke, or insult
NOTE For example, deliberately and repeatedly 3.24 psychosocial risk
mis-pronouncing an individual’s name or making a
combination of the likelihood of occurrence of
verbal assumption about an individual’s skill or ability
exposure to work-related hazard(s) of a psychosocial
based upon a cultural stereotype such as “You must be
nature and the severity of injury and ill-health that can
good at this” based on a stereotype that people of a
be caused by these hazards
similar cultural background are good at something
such as math or technology. NOTE Hazards of a psychosocial nature include aspects
of work organization, social factors at work, work
environment, equipment and hazardous tasks.
3.19 neurodiversity
differences in individual brain function and/or 3.23 reverse mentoring
behavioural traits
practice where the traditional roles of mentor and
NOTE 1 The term is most often used in the context
mentee are reversed
of conditions, such as Asperger’s syndrome or autistic
spectrum disorders, but is not limited to them. NOTE 1 An example of reverse mentoring might be an
employee who is more adapt with social media, who is
NOTE 2 Neurodiversity is a collective noun applied
younger or more junior, supporting and educating an
to groups. Neurodivergence or neurodivergent is the
employee with lesser experience, awareness, familiarity
adjective used to describe individuals.
or knowledge.
NOTE 2 Reverse mentoring can also be referred to as
3.20 organization upward mentoring.
person or group of people that has employees or
customers and a set of functions with responsibilities, 3.24 risk
authorities and relationships to achieve its objectives
effect of uncertainty on objectives
NOTE The concept of “organization” includes, but is
not limited to, a small/micro and medium business, NOTE 1 An effect is a deviation from the expected –
company, corporation, firm, enterprise, government positive and/or negative.
body, authority, partnership, charity, institution or NOTE 2 Objectives can have different aspects, such as
association, or part or combination thereof, whether financial, health and safety, and environmental goals
incorporated or not, public or private. and can apply at different levels, such as strategic,
organization-wide, project, product and process.
[SOURCE: ISO/IEC Annex SL:2012, 3.01, modified] NOTE 3 Risk is often characterized by reference to
potential events and consequences, or a combination
3.21 policy of these.
intentions and direction of an organization as formally NOTE 4 Risk is often expressed in terms of a
expressed by its top management combination of the consequences of an event
(including changes in circumstances) and the associated
[SOURCE: ISO/IEC Annex SL:2012, 3.07] likelihood of occurrence.
NOTE 5 Uncertainty is the state, even partial, of
3.22 protected group deficiency of information related to, understanding or
knowledge of an event, its consequence, or likelihood.
group of people that qualify for protection by law,
regulation, policy or similar directive based upon a [SOURCE: PD ISO Guide 73:2009, 1.1]
specific or set of specific cultural or social characteristics
or traits

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PAS 1948:2023

3.25 social groups 3.32 workplace well-being

groups of individuals recognized by law, or by fulfilment of the physical, mental, social and cognitive
self-identification or self-organization, that share a set needs and expectations of an employee related to
of similar characteristics, traits, views, values, interests their work
NOTE Well-being at work relates to all aspects of
[SOURCE: BS 76005:2017, 3.11 modified] working life, including work organization, social factors
at work, work environment, equipment and hazardous
3.26 stakeholder tasks, and can also contribute to the quality of life
outside of work.
person or an organization that has an interest or an
affect, is affected by, or perceive themselves to be
[SOURCE: BS ISO 45003: 2021. 3.2, modified]
affected by a decision or activity

[SOURCE: BS 76000:2015, 3.24, modified] 3.30 workplace

environment in which an individual performs an
3.27 unconscious bias agreed set of tasks, actions or obligations in accordance
with their job description or accepted definition of
unintended or unintentional assumption, bias or
“work” in exchange for payment or other reward or
prejudice applied to decision-making and other
renumeration
processes that the decision maker is not consciously
aware of NOTE 1 A workplace may be a physical or a remote
location or environment, or a combination of the two.
NOTE Unconscious bias may be based upon social or
cultural traits, but also on the basis of social stereotypes NOTE 2 Workplace environments can differ across
about certain groups of people that individuals form, sectors and industries based upon role and duties. For
and often apply, outside conscious awareness. example, the workplace for a bus driver might include
the bus they drive and the bus terminal or transport
[SOURCE: BS 76005:2017, 3.14 modified] offices, whereas the workplace for an actor or musician
might be the studio, theatre, stage or environment in
which they give interviews. In the case of a professional
3.28 underrepresented athlete or sportsperson the workplace might be
absence or recognition of people in terms of a stadium, pitch, court, arena or field, whereas a
representation or possession of power tour-guide might have a number of varied working
NOTE 1 Underrepresentation of cultural or social environments ranging from open public spaces to a
groups can be an indication of exclusion and could lead formal office space.
to subsequent disadvantage.
NOTE 2 Some cultural or social groups are protected by
laws, regulation or policy or equivalent (protected groups).
NOTE 3 Some jurisdictions may have laws, regulation,
policy or equivalent which might prevent an organization
from openly recognizing some cultural or social groups.

3.29 value
merit and worth of people due to their unique
knowledge, skills and abilities
NOTE In this PAS, “inherent value” refers to the
principle that people are valued for who they are, not
just because they deliver monetary value or money
equivalents to their organization.

[SOURCE: BS 76000:2015, 3.26, modified]

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4 Implementing an effective strategy and framework for

supporting diversity, equity and inclusion across single
and multi-jurisdictional workplaces
4.1 DEI strategy p) laws, regulations, customs and practices;
q) environmental factors;
COMMENTARY ON 4.1
r) compatibility of the proposed strategy with other
It is useful for an organization to establish why a
organizational strategies and initiatives;
diversity, equity and inclusion (DEI) strategy is of
benefit to them and what they hope to gain from s) budget and resource;
implementing one. t) disaster recovery and business continuity;
The most effective way of doing this is to have a u) risks of inaction or doing nothing; and
clear starting point or benchmark which helps the v) anything else that an organization considers to be
organization to understand the following. of impact or relevance to their operations.
• Where is the organization today? NOTE 1 When developing a strategy, organizations
• Where does it want to be? are encouraged to take into account the moral and
• What does it need to do to get to where it ethical rights of individuals as human beings as set out
wants to be? in the United Nations Universal Declaration of Human
Rights 1948 [8].
• What are the key challenges and how will it
address them?
As part of the strategy planning process organizations
• How will it measure and track progress along should conduct a mapping exercise that identifies
the way? key relationships and areas of importance and focus,
This PAS includes a number of simple to use tools including related activities such as psychological health
such as a self-assessment questionnaire and employee and safety management and well-being programmes,
survey templates that organizations can use to assist in and the relationships and integration of different
developing a framework and setting a benchmark. stakeholder and employee forums and groups.

Organizations should assess the impact of diversity, The mapping exercise should explore:
equity and inclusion in relation to the following: 1) links and associations between the organization
a) commercial/business case for diversity; and stakeholders, and the relative importance
b) moral and ethical case for diversity, equity of each;
and inclusion; 2) geographical proximity of stakeholders;
c) organizational values and mission statement; 3) nature and importance of stakeholder relationship;
d) organizational performance; 4) engagement with stakeholders and aligning
e) political, economic and social influences; stakeholder values and principles to the values and
principles of the organization;
f) shareholders and investor relations including
ESG (environmental, social and governance) 5) impact or importance of a stakeholder or value
considerations; or principle;
g) sustainability and ethics; 6) impact assessment of changes to existing
relationships or values or principles; context and
h) employer value proposition (EVP);
impact of future events;
i) psychological health and safety;
NOTE 2 This includes economic and environmental
j) workplace well-being; changes, technology, future markets and changing
k) social and corporate responsibility; customer demographics.
l) brand and market position; 7) cost of changes to stakeholder relationships;
m) product development and innovation; NOTE 3 This includes technology, resource and time.
n) geography (international or national); 8) health and safety management; and
o) stakeholders (customers, clients, suppliers
and providers);

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9) disaster recovery, business continuity procedures in • a governance structure and policy with a clearly
the event of an incident or emergency. defined purpose, mandate and accountability for
NOTE 4 Although this PAS does not provide provisions delivering the organization’s strategy; and
based upon any laws, regulations, policies or other • a designated budget and sufficient on-going
directive, attention is drawn to any laws, regulations, resource (people and technology) for the delivery
policies or other directives that might impact their of the organization’s short-, mid- and long-term
ability to implement or act on the recommendations goals and objectives and overall strategy.
given in this PAS in any jurisdiction(s). 2) Having a set of policies that communicate the
NOTE 5 Different jurisdictions have different laws, strategy, aims and objectives to stakeholders a
regulations, policies and directives relating to the mission or diversity statement, including:
management or recognition and status of different • policies, processes, practices and procedures that
cultural or social groups which might impact upon an are transparently just and fair;
organization’s definition or scope of diversity, equity
• reflecting diversity, equity and inclusion in all
and inclusion.
people management processes from recruitment
NOTE 6 When considering a strategy and framework through to end of employment; and
for diversity, equity and inclusion, organizations can
• bonus, incentive and reward programmes
take into account factors such as local practice, social
reflecting diversity, equity and inclusion targets
mores and attitudes or new trends which might not be
and Key Performance Indicators (KPIs).
supported by law, regulation or similar but which could
have an impact. 3) Verifying that operational practices reflect the
strategy and communicate clearly how the
NOTE 7 Organizations are encouraged to be open
organization expects its policies to be implemented
to and understand the benefits of seeking out and
and actioned, including:
learning from best practice(s) and any new initiatives,
even where such practice(s) cannot be immediately • including diversity, equity and inclusion as a
adapted or applied to their current operations, due to standing agenda point to general/team meetings
legal, regulatory, cultural, social or other restrictions. where appropriate; marketing membership or
support of organizations that support or promote
diversity, equity and inclusion;
4.2 Demonstrating commitment to
• implementing a framework that requires
diversity, equity and inclusion decision makers to demonstrate adherence to
Organizations should agree the best way of the organization’s, diversity, equity and
demonstrating: inclusion strategy;
a) that the strategy is practiced by senior • sponsorship of events that support or promote
management and organization leaders throughout diversity, equity and inclusion;
the organization; and • commitment to supporting or working with third
b) their commitment to diversity, equity and inclusion party organizations focused on diversity, equity
to stakeholders: and inclusion such as organizations owned by
1) inside (employees) the organization; and women or other under-represented groups; and

2) outside (prospective employees, customers, • support charitable and community initiatives,

clients and suppliers/providers) the projects events relating to diversity, equity and
organization. inclusion and underrepresented groups.

Organizations should adopt measures to demonstrate 4) Placing people at the centre of their strategy to
a commitment to diversity, equity and inclusion, taking support accountability and engagement at every
into account the following options. level within the organization, including:

1) Planning a diversity, equity and inclusion strategy • a designated individual responsible for
that outlines what the organization is doing, overseeing, executing, reporting measuring
why it is doing it, how it will do it, and when it will and reporting on the organization’s strategy
do it, including: and strategic initiatives for diversity, equity
and inclusion, such as a Head of Diversity (and
• incorporating strategy in design and research and
Inclusion), or equivalent;
development projects so that new innovations,
products, services, processes and business models • visible diversity among board, non-executive, and
deliver positive outcomes and mitigate any senior appointments;
potential bias in the development process; • hold networking events and support groups for
underrepresented groups;

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• training and development programmes for Organizations should make changes to their brand or
underrepresented groups specifically, including marketing to promote their commitment to diversity,
for leadership roles; and equity and inclusion.
• actively engaging with under-represented
groups such as employees or customers to Commercial or consumer facing businesses should assess
encourage their involvement and input into the how their products and services are presented and
organization’s future plans and strategies. represented to consumers and service users.

5) Measuring performance and tracking progress NOTE 4 For example, the presentation or representation
against the organization’s stated aims and of a product or service might suggest that it is only
objectives through: available or applicable to some social or cultural groups
rather than all social and cultural groups; literature
• annual and interim reporting against agreed
might not be accessible to those with visual conditions;
objectives and Key Performance Indicators (KPIs);
premises or services might not be easily accessible to all.
• external branding through certification and
accreditation to indicate commitment and
achievements;
4.3 Diversity, equity and inclusion policy
• data collection and analysis to help benchmark COMMENTARY ON 4.3
and measure on-going progress; Social, political and economic changes mean that
• providing updates on the organization’s twenty-first century working environments are
performance in relation to legal obligations such multi-generational. Higher or no mandatory retirement
as gender, ethnicity and other pay gap reporting; age, the rise and fall of different industries/sectors
and advances in technology have resulted in people
• annual audit of the diversity, equity and inclusion
working for longer, having multiple careers, and
strategy to measure progress and impact on the
younger senior executives managing mature teams.
organization’s performance;
As a result, organizations need to be aware of the
• formal certification and accreditation and use of a
possible impact of multiple generations working
mark or badge to demonstrate commitment; and
together and how this could result in a clash of
• sharing best practice and benchmarking progress conflicting values, attitudes, and expectations of what
with other groups and organizations. might be considered acceptable conduct or behaviour.
NOTE 1 Diversity, equity and inclusion is about culture This can include, but is not limited to, things such as the
and cultural change. When selecting representatives style, tone and language used in work communications,
for diversity related roles or functions consider all personal appearance and generational attitudes to
parts of the organization so that responsibility does dress, hairstyle or body art in the workplace.
not ultimately rest with those functions traditionally Current broad generational groups within the
responsible for managing people, such as HR. workplace, together with approximate time ranges,
Organizations may identify individuals and allocate are as follows:
leadership responsibilities in accordance with its
• Baby Boomer: born 1946-1964;
diversity, equity and inclusion strategy and aims and
objectives. For example, if the aim is to engage with • Generation X: born 1965-1980;
a more diverse customer base then an organization • Millennial Generation: born 1981-1996;
might allocate the role of diversity lead to an individual • Generation Z: born 1997-2012; and
within the customer engagement or marketing team.
• Generation Alpha: born 2013-present.
NOTE 2 See Clause 6 for more information and guidance.
Organizations need to take generational differences
into account within cultural and social groups and
Organizations should adopt as many of the option(s)
gender related topics as well as providing appropriate
as are appropriate to them and their operating
training and learning to create a fully inclusive working
circumstances and resources.
environment which reduces the risk of generational
NOTE 3 For example, a new organization might based stereotyping.
start with a diversity policy and add other options as
The following characteristics, traits, values and attitudes
they grow, whilst an established organization might
might differ from generation to generation when
consider a policy, stating their commitment in their
developing short-, mid-, and long-term strategies for a
annual report and by making senior appointments with
multi-generational workforce.
diversity in mind.

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PAS 1948:2023

a) World views, including: • value and contribution to the business or team.

• gender classification, expression and c) World and workplace values, including:
identification including stereotyping, multiple • social awareness and expectation of business
or gender neutrality and gender fluidity; for good, corporate social responsibility and
• race relations and ethnicity including racial recognition of ethical and environmental values;
stereotyping and cultural misappropriation; • willingness to take a lower salary for opportunity
• visible and invisible physical and neurological to work for an organization that shares their
conditions including mental health and attitudes, views and values, or expectations that
wellbeing; any contribution (including work experience or
• sexual orientation including expressions and internships) is remunerated; and
displays of identity; and • multi-tasking and multiple careers in a lifetime,
• approaches to parenting, including co-parenting and/or balancing multiple jobs simultaneously.
and same sex/gender parents.
Characteristics and traits include but are not limited In the case of mixed multi-generational teams,
to: age; physical, mental and development abilities; organizations should provide key managers and leaders
marital or civil partnership status; pregnancy, maternity with conflict management training to assist in the
and paternity; having or not having dependants; race; effective and constructive management of generational
ethnic origin; skin colour; social or economic class; differences.
education; military service; caste; language; religious
beliefs or non-belief; political opinion; work pattern Organizations should implement a high-level policy
(part-time working, fixed term contract, flexible which outlines the organization’s approach to diversity,
working, etc.); gender, sexual and romantic orientation; equity and inclusion and is made available to
gender identity or affirmation; or individual’s all employees.
personality, personal interests, lifestyle choices or any NOTE 1 A high-level policy is applicable at the highest
other characteristics that make someone unique. level in an organization and sets out the general
b) Workplace views, including: principles and plan of action to be implemented by
the organization. It is the first, or starting, point from
• working patterns including working from
which other mid- and lower-level policies applicable to
home, re-definition of ‘working day’ and
other levels within the organization can be generated.
work-life balance;
NOTE 2 Early research indicates that the attitudes,
• promotion, career progression, personal
values and expectations of Generation Z are
development and measures of professional
significantly different to those of previous generations
and personal success;
within the workplace including but not limited to
• manager as mentor or equal and reverse attitudes to salary, opportunities to enhance and
mentoring; develop skills and knowledge, management, multi-skill
• frequent feedback on performance and and long-term aspirations and ambitions.
accelerated personal development and
career progression; The policy should include the following:
• level of loyalty to a brand or employer and a) vision or mission statement;
willingness to move if expectations are not met; b) aims and objectives;
• workplace well-being, including physical, mental c) commitment of senior management and
and cognitive health and safety leadership teams;
• entrepreneurial spirt and desire to be recognized d) clear expectations and requirements to support
as a subject matter expert or specialist in field a shared vision across the organization;
• colleagues and co-workers as family and friends; e) recruitment, selection and appointment;
• dress code (including the impact of a dress code f) references to other applicable policies such as
on expressions of religious and cultural identity) those that outline how to report grievances;
and acceptable/appropriate language, behaviour discrimination, harassment or bullying;
and conduct in the workplace; g) relationships with, and applicability to, external
• personal circumstances and situational stakeholders (including customers, suppliers
considerations, such as carer responsibilities or and providers);
women in menopause; and h) brand and marketing guidelines;

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i) support for underrepresented groups and b) HR and personnel and people development teams;
initiatives, including Employee Assistance c) communications, marketing, branding and
Programmes (EAP), “Allies” or “Buddy” PR teams;
programmes and employee networks;
d) individuals and teams responsible or involved in
j) references to other policies where applicable, such the recruitment/hiring process;
as HR or employment policies, or advertising and
e) individuals and teams responsible for health
brand guidelines;
and safety;
k) tracking and measuring progress such as
f) individuals and teams responsible for workplace
commitment to making reasonable adjustments to
well-being;
provide fair physical access to all;
g) individuals responsible for managing individuals
l) listing employee and leaders’ responsibilities and
or teams; and
expected behaviours; and
h) individuals and teams responsible for product
m) consequences of non-compliance.
development and design and delivery of
support services.
Organizations should review and maintain the policy in
accordance with the organization’s policy management
The organization should identify other teams or groups
process and/or the organization’s diversity, equity and
which might benefit from the training, such as those
inclusion strategy.
whose role includes interaction with customers or the
public, or teams where there is a lack of diversity or
As part of the review process, organizations should take
higher rates of employee or staff turnover.
into account employees’ perceptions on which policies
they feel should be implemented, how and by whom. NOTE 2 Training and awareness for individuals
and teams responsible for the product design and
Organizations should make the policy accessible to all development lifecycle supports the organization’s DEI
employees and stakeholders by providing different strategy implementation through-out the supply chain.
language, braille and audio versions, as well as links to For example, how well will a product or application
other relevant or companion policies and documents designed by right-handed or sighted individuals work
such as the employee handbook and grievance policy, for those who are left-handed or partially sighted?
brand and marketing and procurement and supplier/ NOTE 3 Organizations with diverse customers can
provider guidelines. offer targeted inclusive customer care/support training
for customer facing teams focusing on areas such
Organizations should assess whether different as language. For example, the use of terms such as
versions of the policy are needed for use in different “normal skin” as applied to a specific demographic.
jurisdictions or whether this can be supported by
one global policy and a series of supplementary Effective training, learning and development helps
jurisdictional specific versions. employees understand the impact of diversity, equity
and inclusion on organizational performance and
4.4 DEI training, learning and should cover:
development plan • managing revenue, risk and reputation;
• conscious and unconscious bias (see 3.27);
The organization should assess the need for additional
training, learning and development so that employees • relationship between diversity, inclusion
have the appropriate knowledge and skills to be able and innovation;
to implement the requirements of the policy and the • recruitment, selection and retention;
organization’s aims and objectives. • inclusive behaviours;
• cultural awareness (including cultural competence
The organization should provide appropriate training
and concepts of privilege);
on the strategy and how to implement it for leaders
and managers. • managing diverse teams
NOTE 1 Implementation might include training or • brand image and marketing;
re-training in areas such as interview skills and • inclusive customer practices;
techniques, media training, providing feedback or • health and safety and psychosocial considerations;
conflict management for key groups such as:
• appropriate case studies and competitor
a) boards, senior management and leadership teams; comparisons; and

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PAS 1948:2023

• measures of success. Organizations should be aware of the risks of training

becoming, or being seen as, just an administrative
Organizations with high-profile brands should chore or tick-box exercise, with the result that those
assess whether to invest in specialized intercultural attendees who would benefit the most, are also the
competence and media training to avoid the risk of a ones who are the least interested or engaged. To
product development or marketing that is culturally mitigate against this and find a balance, organizations
inappropriate or insensitive. should select training and learning that includes post
NOTE 4 The concept of privilege is the assumption training action points and outcomes linked to the roles
that some individuals or groups of individuals might and responsibilities of attendees.
have automatic advantages and opportunities not NOTE 6 For example, a technical manager introducing a
automatically or easily available to others based upon DEI evaluation to code reviews or someone responsible
one or more characteristics or traits such as gender, for marketing amending brand guidelines to reflect
education, ethnicity, heritage and so forth. based on the training.
NOTE 5 A high-profile brand is a brand which is easily
recognized by the public and/or is able to attract a lot Impact and impact assessments should be designed
of attention or interest from the public or the media. and adjusted to reflect the objectives of the training,
There is no one single solution for achieving diversity, learning and development plan, and include feedback
equity and inclusion goals. from employees on what they found or consider to be
effective and impactful.
In order to meet their aims and objectives,
organizations should adopt an approach that combines Records of training and learning provided should be
a blend of the following: documented and included in any measure of success
or progress.
• targeted training;
• practical initiatives designed to build and increase
awareness; 4.5 Bonus, incentive and reward
• personal and professional development ;
programmes
• performance management to track progress and Organizations that operate an employee bonus or
provide support as and where required; and reward programme as part of the overall renumeration
package based upon organizational, team or person
• a process of continuous learning and development
objectives should take into account diversity, equity and
by offering individuals the opportunity to share and
inclusion performance to underline the importance of
learn from each other’s experiences in a supportive
the strategy and keep it a priority.
environment.
NOTE 1 Organizations can associate a portion or
Organizations should keep their training and other percentage of the bonus to goals and targets relating
learning initiatives up to date and reflect ongoing to specifically to diversity, equity and inclusion.
changes to laws and regulations, as well as on-going
changes in social and cultural attitudes both locally The objectives, goals or targets of the bonus or reward
and globally. programme should be transparent and measurable and
relate to organizational and personal performance,
Employee records should include any further or future covering a combination of hard measures.
opportunities for additional awareness training and NOTE 2 Examples are levels of diversity in the
education that might have been identified through organization or team, and an assessment/appraisal
observation, or as a result of an incident, event or of soft skills and behaviours such as leadership skills,
direct request. training, and employee initiatives that support diversity,
equity and inclusion.
Organizations should report training completion
rates and progress against training targets to senior
teams and/or the Board in accordance with the agreed
strategy for communication evaluation and review.

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Organizations that incentivize diversity, equity and

inclusion should take into account teams where levels
are already in line with, or ahead of goals, or where
implementing targets is not possible and design
measures which do not demotivate or discriminate
against those teams.
NOTE 3 An organization might have an incentive
scheme linked to labour cost or productivity which
could influence recruitment in a way that has an
adverse impact on diversity, equity or inclusion.
NOTE 4 A team within an organization might not be
able to implement some aspects of the organization’s
overall strategy due to local laws or religious or cultural
customs and practices.

Organizations that have existing bonus and rewards

programmes should monitor and review them so that
they do not conflict with, or adversely impact, the
organization’s diversity, equity and inclusion strategy.

Information relating to bonus, incentive and rewards

programmes should be included in annual pay gap
reporting (both internal and external) to prevent a pay
differential in favour of a specific group or groups.
NOTE 5 For example, males receiving a higher annual
bonus than their non-male counterparts, despite all
receiving the same basic salary.
NOTE 6 EDI activities is recognized within workload
models and is as important (e.g. for promotions) as
other areas of work.

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5 Policies, processes and practices for promoting

and supporting diversity, equity and inclusion in
the workplace
5.1 General principles
Organizations should have a set of policies and
practices in place to help promote, support and manage
diversity, equity and inclusion in the organization.
NOTE 1 Figure 2 provides a high-level overview which
can be helpful to organizations.

Figure 2 – Policy to performance

All polices and guidance documents should: e) be available in different formats such as physical
a) be drafted using clear and simple language and digital format, different languages including
that avoids jargon, abbreviations, and technical braille and audio versions, and compatible with
language. Where such terms are included, they accessibility software;
should be supported by a note or explanation; f) be stored in a location or locations that are easily
b) include links to anonymized case studies or accessible to all at any time;
examples that show the intention and purpose of g) be integrated with other policies and practices to
the policy; avoid conflict and any unintended consequences or
c) include references to support mechanisms such impact; and
as union organizations, employee networks and NOTE 2 For example, a Recommend or Refer a
external support bodies; Friend policy could result in a team that is even
d) be issued and/or clearly signposted at the start of less diverse than it started due to individuals
the relationship such as part of an employee or new recommending those similar to them and
starter induction programme or on-boarding of precluding the introduction of individuals outside
new customer or supplier/provider; of existing social and cultural groups.

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h) be reviewed and reissued in accordance with the NOTE 2 Organizations might choose to have policies
organization’s usual policy management process. that cover a number of areas, instead of several
NOTE 3 Organizations might find it beneficial to individual policies. For example, an organization
conduct an exercise to check employees’ and other might choose to have an Equal Opportunities Policy
stake-holders interpretation and understanding of the that also includes information about accessibility or
purpose of the policy as part of the review process. flexible working.

Organizations should add new policies or amend

5.2 Policies existing ones as appropriate to their operating
circumstances and environment.
5.2.1 General
NOTE 3 Some policies may be a legal requirement
Organizations should have in place policies which
of the jurisdiction in which the organization is based
promote and support diversity, equity and inclusion.
on operates.

When producing a policy, organizations should include NOTE 4 Some policies which relate to employment laws
the following: may only apply to some teams such as HR, Personnel
or People team, whilst other policies which relate to
a) who the policy relates to;
conduct and behaviour, such as bullying, harassment or
b) what the policy is about and if applicable how dignity in the workplace, will apply to all employees.
it relates to other policies or the organization’s
NOTE 5 Organization policies in relation to diversity,
diversity, equity and inclusion strategy;
equity and inclusion may include conduct and
c) the organization’s formal position on the matter behaviour both in and outside the workplace and also
or issue that the policy relates to, for example extend to external stakeholders, such as suppliers,
“the organization does not tolerate bullying providers, customers and others who engage or interact
or harassment”; with the organization.
d) how the organization expects the policy to
be implemented;
5.2.2.2 Equal opportunities and anti-discrimination:
e) who the policy is applicable to and why;
COMMENTARY ON 5.2.2.2
f) the organization’s expectation of behaviour and
The purpose of this policy is to create awareness
conduct in relation to the policy;
amongst all prospective and existing employees
g) how the organization intends to monitor that the and make stakeholders aware of the organization’s
policy is adhered to and enforced; intention and expectation that all individuals are
h) the consequences of a policy breach; treated the same, or allowances made to provide
i) the appeal process where a policy includes a right everyone with the same opportunities and without bias
of appeal against a decision or action taken as a or disadvantage or advantage.
result of the policy;
This policy should include:
j) where to find, or who to approach in the
organization for further information or clarification; a) organizational commitment to equity and equity,
covering;
k) who is responsible for maintaining the policy; and
• references to applicable laws and regulations;
l) version control indicating when the policy was
issued and became applicable. • what areas and aspects of the business the policy
relates to and why;
5.2.2 Types of policies • the circumstances under which the policy
applies (such as making reasonable adjustments
5.2.2.1 General
to support employee needs) as well as the
The organization should review the types of policies it circumstances where it might not apply
should have in place and who they should apply to. (if applicable);
NOTE 1 Examples of the types of policies organizations • the processes and practices employed to support
can implement are provided in 5.2.2.2 to 5.2.2.11. equal opportunities and prevent discrimination;
• how employees can raise a concern or issue;
• an appeal process if the request is refused; and
b) where to find further guidance and support.

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5.2.2.3 Accessibility NOTE 3 In some jurisdictions, such as the United

COMMENTARY ON 5.2.2.3 Kingdom, harassment is associated with protected
groups and included in laws and regulations and needs
The purpose of this policy is to make sure that
to be reflected in the policy, whereas other jurisdictions
individuals who require additional or reasonable
have specific laws and regulations that cover training or
adjustments to working practices and environments to
processes and practices for some forms of harassment
be able to perform in the same way as everyone else
such as mandatory sexual harassment training
are appropriately supported.
and awareness in some US states or investigative
committees in India.
This policy should include:
a) the organization’s commitment to accessibility; 5.2.2.5 Grievance policy
b) accessibility for those with visible or invisible COMMENTARY ON 5.2.2.5
conditions (employees, customers, providers); The purpose of this policy is to allow any individual
c) changes to physical environment or access to who feels that they might have been treated unfairly
assistive technology and tools and support for or as a result of a breach of the organization’s policies
those with conditions; and practices is able to raise their concern and that it
d) changes to working practices (for example holding will be investigated in an appropriate manner by the
meetings at times or using media such as video organization.
conferencing that work for all such as parents,
carers); and This policy should include:
e) Employee Assistance programmes and initiatives to a) a definition of the term “grievance”;
support accessibility to tools and support as well as b) when an employee should raise a grievance;
general well-being. c) how to raise a grievance;
NOTE This would be expected to include provision d) what happens once the report has been made; and
of health and safety controls and psychosocial risks
e) the right of appeal process.
(for example, gender specific work equipment or
clothing, fire alarm systems that support those with
Organizations should provide training on performance
hearing impairments, nursing mothers, adaptive
management, including understanding how individual
work stations, etc.)
and team performance can be impacted by poor or
5.2.2.4 Harassment, bullying and victimization unfair treatment by those around them, to those
responsible for managing and supervising the
COMMENTARY ON 5.2.2.4
performance of others.
The purpose of this policy is to outline the
NOTE 1 A grievance policy is a formal way for raising
organization’s position and approach to any form of
a concern relating to discrimination, unfair treatment,
harassment, bullying or victimization.
harassment, bullying or circumstances in which an
employee has observed, or been the victim of conduct
This policy should include:
or behaviour which is abusive, insulting or offensive.
a) the organization’s position on an employee’s right
to dignity and respect at work; Organizations should create a simple process for an
b) the expected standard of conduct and behaviour; individual to raise a grievance by identifying and
c) definition of discrimination, victimization, removing any perceived or actual barriers or obstacles
harassment and bullying; to reporting or raising a concern. This should also apply
to whistleblowing.
d) what an employee should do if they are feel they
are a victim of harassment or bullying, or if they see NOTE 2 It is common for someone who is the victim
someone else being harassed or bullied; of harassment, bullying or undignified behaviour or
conduct to talk to a friend or colleague about it first.
e) how to report harassment and bullying;
f) what happens once a report has been made; and The organization should consider how it can provide
g) the right of appeal process. ways to support the friend or colleague to raise their
NOTE 1 Some organizations refer to this policy as a concerns without breaching confidence or trust, such as
“Dignity at Work” policy. providing information on “What to do if your friend or
colleague is being bullied”.
NOTE 2 Victimization can be as a result of being the
target of harassment or bullying, or as a result of
raising a complaint (or grievance) about harassment,
bullying or other concern relating to conduct,
behaviour or treatment.

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Where possible, where a grievance is about or relates workplace, such as a change in working hours to better
to a specific group, characteristic or trait, any appeal support childcare responsibilities.
process or panel reviewing the outcome should
have individuals who are representative of the issue This policy should include:
(for example, if the grievance relates to female a) the circumstances under which an employee can
discrimination, the appeal or review panel should raise a request for flexible working (including
include female), including independent external working from home);
individuals.
b) how to raise and request; and
5.2.2.6 Disciplinary policy c) the right of appeal process.
All organizations should communicate the conduct and NOTE 1 In some jurisdictions, employees might have a
behaviour considered to be unacceptable (misconduct legal right to request flexible working.
or gross misconduct).
NOTE 1 This can result in a warning or dismissal gross, Health and safety policies and management of
depending on the severity of the offence at the start of psychosocial risks should extend to all aspects of flexible
their employment. and remote working.

NOTE 2 Most organizations have a disciplinary policy Where flexibility is offered organizations should take
or process. care that this is applied to all.

The types of conduct and behaviour that are contrary NOTE 2 For example, flexibility for parents is applied to
to an organization’s position on diversity, equity and all parents and not just mothers.
inclusion should be included in the disciplinary policy
Organizations should also apply this to business
together with the level of severity.
continuity and disaster recovery processes which
NOTE 3 Conduct and behaviour linked to laws and require a change or deviation to normal or established
regulations are usually considered to be more severe. working practices are as inclusive as possible providing
additional support and/or equipment for those
Conduct and behaviours which the organization should
who need it, such as employees whose domestic
cover in its disciplinary policy are:
arrangements or circumstances do not easily support
a) harassment; working from home.
b) bullying;
5.2.2.8 Parental and adoption leave
c) discrimination;
COMMENTARY ON 5.2.2.8
d) victimization;
The purpose of this policy is to give all parents
e) conduct or behaviour that is offensive, abusive or
irrespective of gender or role the same rights,
insulting; and
irrespective of biological considerations.
f) conduct and behaviour which is considered a
breach of the organization’s position on diversity, This policy should include:
equity and inclusion. a) the legal rights of parents in the workplace;

The disciplinary policy should state whether the policy b) additional rights and benefits provided by the
applies to the workplace or is also be applied to organization;
conduct and behaviour outside of the workplace. c) the practical application of rights and benefits;
d) how the employee should raise any issue(s);
Organizations that interact with the public should also
e) what support and assistance the employee can
have customer facing policies supporting diversity,
expect from the organization; and
equity and inclusion which are designed to protect
employees from abuse and harassment from customers. f) the right of appeal process.

5.2.2.7 Flexible, hybrid and remote working: Parental and adoption leave should be offered on
COMMENTARY ON 5.2.2.7 equal terms to parents of all genders.

The purpose of this policy is to provide individuals in

an organization the opportunity to request a change
to their normal working patterns to support changes
in personal circumstances or events outside of the

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5.2.2.9 Health, safety and wellbeing c) how the concern is investigated and what action
COMMENTARY ON 5.2.2.9 might be taken;
The purpose of this policy is to show an organization’s d) how the employee raising the concern is protected
commitment to safeguarding the mental health and from any negative action or consequence as a result
wellbeing of employees and stakeholders. of raising the concern.
NOTE In some jurisdictions raising a concern about
This policy should include: wrongdoing (especially any action which might be
a) what the policy covers; considered illegal or in breach of laws or regulations)
can also be referred to as a “protected disclosure”.
b) how the employee raises an issue;
c) what support and assistance the employee 5.2.2.11 Brand/marketing guidelines
should expect; Organizations should assess how their diversity, equity
d) information about employee assistance and inclusion strategy impacts their brand and issue
programmes; and guidance to marketing and advertising teams.
e) information about external organizations and
support agencies. Existing brand and marketing guidelines should be
updated to reflect the organization’s approach to
Health, safety and well-being policies should be diversity, equity and inclusion to include guidance on:
reviewed and updated as necessary to verify that the a) the use of language or terminology;
physical, mental and cognitive health and well-being of b) the use of images and other visual representations;
employees is effectively covered.
c) marketing and advertising that is accessible to all
NOTE 1 Organizations need to be aware of the ways including those with conditions;
in which they can impact on the mental, emotional,
d) organizational and corporate communications
physical, financial and/or social wellbeing of an
to promote and highlight diversity, equity and
individual and reflect this in their practices and
inclusion initiatives both internally and externally;
processes. This includes but is not limited to stress and
pressure caused by deadlines or targets, working long e) the use of employee success stories subject to
hours or a lack of reasonable breaks, workload and employee consent process; and
duties in excess of the role or job description, pressure f) a review and sign-off process.
to conform and factors outside of the organization. NOTE Use language that is appropriate and best suited
NOTE 2 Organizations might also need to consider to the organization and its operations. For example, in
health and mental wellbeing awareness training to some locations the term “disability” might be used, but
help managers identify employees who might need in others the more common or acceptable term may be
additional help or support. “impairment” or “condition”.
NOTE 3 Organizations have a responsibility to be aware of
5.2.3 Monitoring and audit of policies
any laws and regulations applicable to the jurisdiction(s)
in which they operate or have operations, including the Organizations should establish a process for monitoring
requirement to consult with employees or stakeholders. and auditing its policies against its stated aims and
objectives for diversity, equity and inclusion, and make
recommendations for improvement.
5.2.2.10 Whistleblowing
COMMENTARY ON 5.2.2.10 The monitoring and audit process should cover:
The purpose of this policy is to inform employees and a) employee awareness of and access to the policies;
stakeholders who speak out about wrongdoing, either b) how different employees interpret the same policy;
by an individual linked to the organization, or by the
c) if any employee has raised a request, issue or
organization itself can do so safe in the knowledge that
concern and what how it was managed; and
they will be protected.
d) whether policies are applied fairly and consistently
This policy should include: across the organization.
a) how any employee can raise a concern about NOTE 1 The audit aims to understand the effectiveness
wrong-doing or inappropriate, illicit or illegal of the policy, including whether employees are
behaviour or conduct of an individual, team or the reluctant to rise issues or concerns. For example, if
organization; there has been no request for flexible working, is this
because employees are not aware of the policy, because
b) the right to confidentiality and anonymity and how
no-one wants flexible working or because employees
the whistle-blower’s identity is protected;
are reluctant to raise a request.

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NOTE 2 The audit also aims to identify any common j) regularly reviewed and amended.
trends or patterns. For example, exit interviews
all stating similar reasons for leaving, or some 5.3.2 Monitoring and auditing of processes and
leavers giving no reason at all; a higher number of practices
performance management concerns in relation to a Organizations should develop a process for monitoring
specific group of employees, or a lower number of and auditing its processes and practices against its stated
requests for flexible working from one team compared aims and objectives for diversity, equity and inclusion.
to others in the organization.
Monitoring should be undertaken by an independent
Organizations should determine how best to apply the assessment such as internal audit or risk and compliance
practices and policies implemented or mandated in one and by personnel who have received appropriate
location across all of their locations to maintain global training including identifying conscious and
uniformity. For example, if gender pay gap reporting unconscious bias.
is applied in one location it should be applied to all
locations (where laws and regulations permit, or do Processes and practices should be assessed at every
not prohibit). stage for effectiveness at least once a year to support
ongoing and continuous improvement and delivery
against objectives.
5.3 Processes and practices
The monitoring and audit process should assess
5.3.1 General principles
the following:
Organizations should have processes and practices in
a) accuracy and adaptability of job descriptions;
place to monitor that policies are implemented and
enforced consistently throughout the organization, b) impact of advertising and recruitment methods;
and at all times. c) source and quality of applicants;
d) evidence of bias in the applicant screening process;
Guidance should be provided to individuals and
e) evidence of bias in the interview process;
teams responsible and accountable for the approval,
communication, implementation and enforcement of f) measure success against internal targets;
the processes and practices. g) track internal progression and development of
NOTE For example senior management teams, employees; and
non-executive directors, risk and compliance, marketing, h) make recommendations for improvements
company secretaries, investor relations, HR and heads as applicable.
of departments.
Organizations should apply the same monitoring
Wherever possible processes and practices should be: and auditing to the promotions and internal transfer
a) formalized and available in a variety of formats process to confirm that diversity, equity and inclusion
such as print media, audio, screen readers, large is also reflected in the internal recruitment process,
typeface, etc.; tracking progress by comparing promotion metrics with
other comparable teams and departments rates levels
b) transparent, fair and easy to understand;
of diversity.
c) in language that is inclusive and does not favour
or appear to favour any particular social or Organizations should include the following metrics
cultural group; and data points as part of their monitoring and
d) available to all employees; auditing measures:
e) applied consistently across the whole organization; 1) career progression and development:
f) supported by additional awareness, training, • promotion rates by characteristics and traits;
learning and development, as required; • pay gaps (including averages and bonus, benefits,
g) monitored to check that they are implemented and rewards);
properly and as intended; • career development programmes as applicable to
h) measured to track results and outcomes; different groups ;
i) communicated to external stakeholders using • diversity of colleagues undertaking different
appropriate methods such as via the organization’s types of training, learning and development;
website; and

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• diversity of colleagues being sponsored to do • rate of return from parental leave;

further education courses; • take up of shared parental leave; and
2) recruitment and selection: • grievance data by diversity (including numbers of
• application; reports, reasons and outcomes/decisions).
• shortlist;
5.3.3 Recruitment
• offer;
• acceptance; 5.3.3.1 General

3) culture: Organizations should include processes and practices that

support diversity, equity and inclusion at all stages of the
• diversity data by role, location, pay band,
recruitment and selection cycle, as demonstrated in
business area;
Figure 3. Organizations should assign individuals within
• attrition (turnover) including rates and numbers the recruitment and selection process performance related
of leavers and reasons; objectives that support the organization’s diversity, equity
• diversity data – workforce engagement survey; and inclusion goals and objectives.
4) equity: NOTE 1 This includes collecting and sharing anonymized
• flexible working (requests made, granted, demographic data at every stage of the process
and denied); from numbers of applicants from different groups to
selection, interview, offer and appointment.
• diversity data of colleagues requesting reasonable
adjustments (requests made, granted, denied);

Figure 3 – The recruitment cycle

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Available roles should be communicated and be open Where there is no requirement for any previous
to all suitably skilled and qualified individuals. experience or specific qualification, such as
entry-level roles or where training is provided following
The recruitment process should be accessible, and appointment, organizations should recruit on the basis
support applications from candidates who have of a candidate’s potential to increase levels of diversity
medical conditions. and inclusion.
NOTE 2 This can be achieved by considering alternatives NOTE 1 When writing job descriptions and role
to traditional interview techniques, such as written or requirements, avoid broad terms that rely on the
verbal assessments and skills tests, short presentations applicant or interviewer to make a subjective
or environmental assessment where candidates spend assessment based on their personal interpretation
time with the team they would be working with and based on existing biases. For example, “desirable skills”
both parties provide feedback to the interviewer. can be interpreted as essential or a key requirement,
resulting in good candidates being disregarded or
Organizations should analyse the demographic choosing not to apply. “Personality fit” could imply
representation within their organization and compare or include cultural or social characteristics or traits.
it to that of the wider locations in which they operate “Required to travel” as a general term might deter
to check that the demographic make-up of their candidates with domestic commitments, but “required
employees reflects that of the locations in which to travel to Munich office twice a year” might allow
they operate. those same candidates to consider the role differently.
NOTE 2 Unless specifically required by law or
Where an organization is applying a strategy of quotas
regulation, avoid phrases in role requirements that
or positive discrimination or action the reasons for this
introduce biases. For example, linking experience
should be clearly communicated. Where this is applied
to time, “must have at least five years’ experience”,
candidates should be asked to provide their consent to
which introduces a bias of quantity over quality and
being a part of such an initiative.
automatically disqualifies suitably skilled applicants.
NOTE 3 Organizations can voluntarily publish data or
NOTE 3 Review job descriptions for signs of bias, such as
information in relation to equal pay where they are not
use of language or imagery that might appeal to only
compelled to do so by law or regulation. For example,
some social or cultural groups. For example, “would suit
where an organization is encouraging applications from
mother returning to work”, or “retired person”.
specific social or cultural groups with appropriate skills
and experience in order to increase the number NOTE 4 Use gender neutral language and review job
of applications and appointments from descriptions for signs of bias. For example, use of
underrepresented groups. language or imagery that might appeal to only some
social or cultural groups, or terms such as “team player”
NOTE 4 Some jurisdictions have laws and regulations
or “good communication skills” where these are not a
that require organizations to actively encourage
requirement of the role.
applications from under-represented groups. This could
be through direct laws and regulations such as equal Organizations should review:
opportunity and anti-discrimination laws, or indirectly,
• whether a job description can be adapted to support
such as gender or race pay gap reporting which would
flexible working or job sharing between individuals
help highlight existing biases in an organization that
with complimentary skills that meet the requirements
require attention.
of the role without any negative impact;
5.3.3.2 Job descriptions • whether a job description or the physical environment
Each role should have a formal description stating can be adapted to support an individual with a
the duties, responsibilities, qualifications, skills and condition without any negative impact; and
experience required for the role, working terms and • any financial or other support such as subsidised
conditions, renumeration package (if included) and travel, availability of equipment or an allowance
reporting structure. to assist with the cost of remote working from a
personal or non-organizational location.
Job descriptions should focus on the competencies
required for the role and be clear and objective and not Where possible, organizations should make reasonable
open to interpretation. adjustments and assess the possibility of job sharing to
support medical conditions and neurodiversity.

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In addition to making adjustments to the interview d) A statement can be made that the organization
process, organizations should assess if making welcomes applications from underrepresented
adjustments can be made to the physical work groups, and affirming its commitment to promoting
environment where it is reasonable to do so. and supporting diversity, equity and inclusion.
NOTE 5 Annual workplace risk assessments allow e) Any affiliation, sponsorship or support of any
organizations to monitor the ongoing impact on charities, organizations, events or initiatives in
employees and make adjustments as required such relation to diversity, equity and inclusion.
as filter screens for computer monitors or assistive NOTE 5 For example Women in Tech initiatives or
technology. Pride (an annual event in support of LGBTQIA+
communities).
5.3.3.3 Advertising
Organizations should have a plan for advertising Organizations should assess the benefits of recruitment
roles in such a way to attract a more diverse range initiatives which target specific under-represented
of applicants. cultural or social groups such as:
• employee referral programmes such as “Recommend
The following areas should be taken into account.
a friend or candidate”;
a) Where roles are advertised, including information
NOTE 6 “Recommend a friend” programmes can
around accessibility and the target audience for
carry the risk of disproportionately increasing
that resource.
the representation from an existing group or
NOTE 1 For example, advertising a role in a demographic unless appropriate monitoring controls
publication or marketplace where the target audience are applied. For example, a RAF scheme applied to
is a specific gender or ethnicity has an impact on the a team or department made up of mainly veterans
gender and ethnicity of the applicants, or ensuring is likely to result in the recommendation of other
that information is easily accessible to a visually or veterans rather than younger candidates.
otherwise impaired applicant.
• open days (where prospective applicants are invited
NOTE 2 Information can be included about financial to visit the organization to learn more about how it
support such as subsidized travel to and from work, works and the opportunities it offers) in collaboration
or supply of equipment or allowances to support with charities or community groups;
costs related to remote working such as internet
• work experience and internships which allow
provider or increased energy usage.
individuals to gain (paid or unpaid) experience of
b) The language and tone of voice used in advertising working in the organization for a period of time;
and whether it communicates a bias or leaning to
• apprenticeships and opportunities for those returning
specific social or cultural groups.
to work after a period of time away due to personal
NOTE 3 For example, phrases such as “regular or other circumstances such as injury;
overseas travel” or “required to be on-call” might
• short-term placements or secondments which allow
deter applicants who are parents and are to be
an individual the opportunity to undertake another
avoided (unless they are a true requirement of the
role within the organization for a period of time; and
role), compared to more inclusive phrases such as
“opportunity to work from home” or “flexible • recruitment fairs which are be linked to cultural
hours” or “flexible working”. celebrations and gatherings.
c) Imagery used alongside any role should reflect and
Those responsible for recruiting (including interview
reinforce the organization’s position on diversity,
and selection processes) should be representative of
equity and inclusion.
different groups within the organization. They should
NOTE 4 Organizations can consider the use of make recommendations for additional support in the
language or imagery which could be perceived to workplace for successful candidates.
be targeting or excluding a specific social or cultural
NOTE 7 Organizations can consider how they offer
group or could be seen as being interculturally
underrepresented groups the opportunity to acquire
inappropriate or insensitive to any social or cultural
skills, knowledge and experience within the workplace
group. For example, an image showing mainly or
or for specific roles using internships or short-term
only men might give the impression that the role is
placements. This could apply to existing employees
for men only, or an image showing a cross section
within the organization or through partnerships
of the workforce where the senior employees are
with community, government or charity associations,
represented by one social or cultural group, and
rehabilitation/back to work programmes and initiatives
more junior employees represented by a different
that seek to promote, support, re-skill or re-train
social or cultural group might give the impression
and place individuals from underrepresented groups
that role and seniority is linked to a candidates
as well as individuals such as veterans and armed
social or cultural background.

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forces personnel, obsolete trades and professions, NOTE 2 This could take the form of a technical test such
individuals with disabilities, older employees and those as asking a candidate for a developer role to complete
formerly incarcerated in rehabilitation and recovery a code review, or a candidate for a customer support
programmes. role to respond to a dummy customer complaint.

Organizations that outsource recruitment to external Unless required as part of the referencing or due
agencies should share their aims and objectives with diligence process, organizations should also remove
the agency and provide clear instruction and guidance information relating to educational institution(s)
as to how they expect the recruitment process to to reduce the risk of bias, focusing solely on the
be managed. qualifications required for the role.
NOTE 8 For example, stating that they would like NOTE 3 Anonymized (or blind) screening is not a
to see a gender balanced mix of applicants, or that fail-proof method. For example, previous role
they would like an agency to work with specific descriptions, or names and locations of previous
charities or community grounds to increase levels of employers or educational institution(s) attended might
underrepresented groups. provide an insight into the cultural background of the
applicant, or introduce new bias based on the assessor’s
5.3.3.4 Employer review websites/forums personal views about employers or educational
Organizations should use employer review websites institutions.
and forums that allow employees to share information
and post reviews about their employer/organization as 5.3.3.6 Evaluation of applicants
a way of promoting and showing their commitment to Organizations should create a scorecard that evaluates
diversity, equity and inclusion. each applicant against a consistent set of criteria.
NOTE 1 Examples include www.workology.com,
www.glassdoor.com and www.fairygodboss.com. The score system should allocate points based on
how the applicant matches the requirements of the
Organizations should encourage employees to share job description.
their views so that prospective applicants are able to NOTE 1 One approach is to assign a point to each
see what previous and current employees think about requirement within the job description. Each time
the organization, how they treat employees and the the applicant meets a requirement they are awarded
workplace culture and environment. a point. The applicants with the greatest number of
points are the ones that are the closest match to the
Organizations should monitor such sites to measure job description and therefore the ones most suitable for
and assess employee perceptions and views regarding the role and the first to move to the next stage of the
the organization as a place of work with a view to recruitment process. For example, if the requirement
investigating and taking appropriate action to address is “must have experience developing invoices”, every
any trends or issues. applicant who indicates experience developing invoices
NOTE 2 Organizations need to be cautious of is awarded a point.
addressing negative comments or reviews by posting NOTE 2 Some requirements might carry a range
their own positive comments or reviews as this rarely of points depending on the degree to which the
works other than to show the organization in an even applicant meets that requirement. For example, the
worse light. Where sites allow an employer to respond requirement “must have experience of managing
they need to do so professionally and in accordance teams” might be broken down into a range of points
with the site rules. based on the size or location of teams and an applicant
that has managed large or multiple teams might score
5.3.3.5 Anonymized screening of applications higher than a candidate that has managed small or
Organizations should apply anonymized screening. fewer teams.
NOTE 1 This is also referred to as “blind” screening. This
technique involves removing any personal information This scoring system should be used to produce
that might give insight into an applicant’s gender or a shortlist.
cultural or social background, so that any assessment
of their suitability is made solely against their skills, Applicants should be scored anonymously based on
experience and qualifications. how they compare to the job description, so that where
positive discrimination or action is applied, only those
candidates whose scores are at least the same as those
of candidates not recruited by positive action
are shortlisted.

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5.3.3.7 Structured interview process Where the process has a number of stages, the
Organizations should have in place processes which process and timings should be communicated at
support an objective and transparent interview process the start as well as after each stage to provide
that limits the risk of bias. assurance and minimize any undue stress or anxiety.
Organizations should:
To achieve this, organizations should: i) complete interview notes that state the reasons for
a) conduct interviews with suitably qualified and why a candidate was suitable or unsuitable, or why
trained employees; one candidate is preferred for a role over another;
b) support an untrained or inexperienced employee ii) incorporate questions relating to diversity,
conducting an interview by providing a suitably equity and inclusion in interviews for senior and
qualified/experienced colleague or a member of managerial roles;
the HR/People team; iii) offer flexibility when scheduling date and times
c) where possible, use at least two interviewers, each for interviews to accommodate parental or other
representing different cultural and/or social groups commitments, and offer, if appropriate, financial
for balance; and assistance for, or reimbursement of, travel costs for
in-person interviews;
d) follow a pre-defined score-based interview
structure, where all candidates are presented with iv) provide sufficient notice and any other material
the same set of questions in the same way and their information such as how to get to the location, who
answers documented accurately. to ask for on arrival and what to expect; and
v) use methods such as assessments, round table
Each question should carry an objective score based discussions, and the submission of a written
upon the expected answer(s) to that question. paper or presentation using screen readers,
Organizations should: audio recordings and other alternatives, to allow
1) clearly document questions or responses that do applicants to demonstrate their competencies.
not form part of the score, together with the
5.3.3.8 Employee induction and onboarding
reason for the question; and
Organizations should use a structured induction and
2) where possible, use, at a minimum, a two-stage
onboarding process for employees that are new to
interview process. Where a two-stage process is in
the organization.
place the first set of interviews should be based
on the applicants who scored highest during the
This process should be applied to employees changing
applicant screening process. The second set of
roles or locations in the organization.
interviews should be based on the applicants who
scored highest in the first set of interviews.
An employee induction programme should include:
NOTE 1 Organizations can make reasonable
a) the organization’s vision, strategy, aims
adjustments for candidates who need questions to
and objectives;
be provided in a different format, such as written
or with the aid of a translation, or in advance b) why diversity matters in the organization and
where they might need more time to prepare how it fits into the overall corporate strategy if
compared to other candidates. not already included in a);

NOTE 2 There is no limit to how many stages an c) the role and responsibilities relating to the
organization can apply to an interview process; employee, including contributing to the
however, it is good practice for organizations to organization’s vision and how to get involved;
consider how an interview process which requires d) copies of, or access to, employee policies and
a candidate to make themselves available for procedures, including the right to membership
a prolonged period of time or on a number of of external associations or organizations such as
occasions might impact on candidates with personal trade unions;
or caring responsibilities. e) training and personal development opportunities;
f) information about support and network groups,
and other initiatives designed to support
underrepresented groups; and
g) any other information that supports diversity,
equity and inclusion, including confidential
helplines, counselling, flexible working, and other
support mechanisms.

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Employee induction/onboarding programmes should be 5.4 Addressing behaviour inconsistent

reviewed annually to keep them up to date with, and with DEI
relevant to, the organization and its aims and objectives.
NOTE When developing induction and onboarding 5.4.1 General
programmes, organizations should take into account Organizations should use employee personal
different delivery styles and techniques, formats and development plans to support their diversity, equity
language so that they are as inclusive as possible. and inclusion objectives.
5.3.3.9 Exit interviews
Personal development plans should communicate that
Organizations should use structured exit interviews as the responsibility for achieving the organization’s goals
a means of recording levels of employee turnover and applies to all employees within the organization.
the reasons for leaving, allowing organizations to:
a) identify the policies, processes and procedures Performance objectives should be constructed to reflect
that are working or not, and those that require organizational, team and individual contributions to
future development; the overall diversity, equity and inclusion strategy, and
b) investigate and address any underlying concerns or include but are not limited to:
issues not raised in the workplace; a) recruiting against diversity, equity and inclusion
c) identify trends or patterns (positive and negative); targets;
d) understand what needs to be done to support b) secondments, work experience, internships,
ongoing improvement; and apprenticeships and return-ships;
e) identify specific social or cultural groups where c) job shadowing opportunities and reverse
levels of turnover are above average and the mentoring programmes;
reason(s) for this. d) supporting internal or external diversity, equity
NOTE Organizations can use a variety of objective and and inclusion initiatives;
subjective open-ended questions relating to diversity, e) keeping internal and external contact details
equity and Inclusion, such as “Do you think the current, and accessible;
organization treats all employees fairly or in the same f) attending or implementing training, learning and
way?”, or “When was the last time you felt excluded?”. development;
g) providing feedback and coaching;
To maintain the integrity of the process and encourage
honesty, exit interviews should: h) evaluating and assessing progress to understand
the reasons for any under or over performance;
1) be confidential, and employees should be made
aware of this before the interview; NOTE 1 This could be as result of training, skills or
ability, or as a result of targets or objectives being
2) be conducted by the HR team or third-party
too ambitious or too simple;
vendor; and
i) agreeing a plan of action to address any issues or
3) have the option to be completed anonymously and/
concerns; and
or after leaving the organization to minimize any
potential for retaliation. j) assessing the risks and unintended consequences
of quotas/positive discrimination or action.
The content of interviews should be shared in an NOTE 2 Individual personal development plans can
anonymized way with only those who require the include performance targets but also actions for future
information. development including, but not limited to:
• arranging appropriate secondments, work experience
Exit interviews should be maintained and used as and internships for individuals looking to develop
part of the monitoring and audit process in accordance their career;
with 5.3.2.
• becoming a mentor or assigning a mentor to support
career development; and
• attending training or providing additional learning
and development opportunities.

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NOTE 3 Personal development plans for individuals Organizations should provide diversity, equity and
responsible for managing or leading teams may include inclusion awareness training and learning and
specific performance measures relating to diversity, development opportunities for all employees.
equity and inclusion.
NOTE 4 Where personal development plans include Organizations should also assess the benefits of
such performance measures and targets, organizations training, learning and development relating specifically
can provide guidance and additional training and to diversity, equity and inclusion which would be of
ask about adjustments or changes that might help to benefit to everyone in the organization.
verify that they have the appropriate skills to be able NOTE 2 Examples of training, learning and
to support their peers to identify objectives relating to development courses include but are not limited to:
diversity, equity and inclusion. • conscious and unconscious bias;

5.4.2 Developing and procuring training, learning and • intercultural competence;

development programmes • intercultural team building; and
Before investing in brand new training programmes, • education about specific dimensions of diversity
organizations should first assess their existing training, (e.g. people with disabilities, LGBTQIA+, etc.).
learning and development offering to adapt them to
support diversity, equity and inclusion. 5.4.3 Mentoring and reverse mentoring
NOTE 1 Examples of existing training offerings that In addition to traditional mentoring techniques,
might be adapted to include training about diversity, organizations should introduce the concept of “reverse
equity and inclusion are: mentoring”, where an employee who is a subject
• recruitment and selection; matter expert (SME) but is in a more junior role or
• interview skills; position shares their knowledge and skills with those
• customer engagement and customer relationship in more senior roles in areas such as:
management; a) new and emerging technology and its uses;
• disciplinary and grievance; b) current attitudes, values and views;
• conflict management; c) language, conduct and behaviour traits;
• health and safety; d) social media and interactions; and
• mental health and well-being; e) social characteristics and emerging trends.
• employee coaching and development;
• inclusive leadership and management skills; 5.4.4 Integration and support networks
• focus groups, where employees are invited to share COMMENTARY ON 5.4.4
their experiences and learn from each other; Organizations are advised to have initiatives in place
• interpersonal skills, providing guidance on how to for ensuring that individuals from underrepresented
create a safe and open environment; groups are fully included in the organization and
are encouraged to provide feedback and speak up
• inclusive interaction, conduct and behaviour in the
about inequality and inequity in a supportive way.
workplace including informal conversation, office
The organization has a responsibility to monitor
“banter” and jokes;
that no employees feel less valuable, less included or
• procurement and commissioning and third-party disadvantaged because of social or cultural differences.
relationships;
• media training for individuals who might be required
to communicate, represent or speak on behalf of the
organization in public or through the media, such as
newspapers, radio or television; and
• supporting external initiatives such as “Women/Girls
in Tech” or organizations seeking to place
ex-offenders or impaired individuals into the
workplace through training, work experience,
internships or apprenticeships.

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5.4.4.1 Inclusion Organizations should include employees from all

groups in the decision-making process for social and
5.4.4.1.1 Work-based events team activity.
Organizations should take into account the benefit
of organizational events that bring everyone in the Organizations should take into account using social
organization, or large groups of employees, together activities as a way of bringing together teams from
in one place. different business functions to broaden the reach of
diversity and promoting inclusion across the whole
Underrepresented groups should be asked to provide organization.
feedback about what the organization can do to
support them, including recommending the types of Social events should not draw attention to
initiatives, events and employee groups they feel would underrepresented groups in such a way as to highlight
be most beneficial or appropriate. them as a minority or marginal part of the workforce.
NOTE 1 Such events can be used to communicate:
Organizations should focus on events that relate to
• organizational performance;
general or popular themes such as:
• organizational strategy and future plans;
a) organizational anniversaries;
• celebrate champions (both teams and individuals); and
b) UN International Days;
• highlight success stories.
c) cross-cultural and religious celebrations;
Organizations should use times and locations that are d) charity initiatives such as dress-down or
as inclusive as possible, with travel to and from the themed days;
event if outside of the workplace and normal working e) local and community events;
times supported by the organization. f) popular and sporting events; and
NOTE 2 Events can be physical, virtual or a combination g) team building days and events.
so that they are as inclusive as possible.
The event venue should be assessed for physical and
In the case of a physical event, venues should be cultural accessibility, so that employees with physical
assessed for physical and cultural accessibility, so access needs, such as wheelchair users, or employees
that employees with physical access needs, such who would not normally visit venues that serve alcohol
as wheelchair users, or employees who would not for religious or cultural reasons, are not excluded.
normally visit venues that serve alcohol for religious or
cultural reasons, are not excluded. 5.4.4.2 Support groups and networks
NOTE 3 For example, checking that facilities support COMMENTARY ON 5.4.4.2
those with conditions and schedule timings allowing Organizations are advised to establish or allow
for breaks for prayers. employees to establish support groups and networks
for different social and cultural groups within the
Speaker and presenter lists should be reviewed to assess organization.
the level of diversity reflected and any possible impact
Where there is no tradition or historical precedent for
in relation to this on the audience.
such groups and networks within the organization,
5.4.4.1.2 Social events clear communication that the organization is open to
and willing to support the establishment of such groups
Organizations should take into account the role of
in accordance with its diversity, equity and inclusion
social events as a means of helping to break down
strategy is necessary.
cultural and social barriers, increasing understanding
and acceptance of differences and supporting This is especially the case in circumstances where there
integration of underrepresented groups, on a team, site might be hostility or suspicion towards a group due to
or organization basis. wider political, social, religious or cultural issues beyond
the immediate control of the organization.
Social events should take place both inside and outside In establishing such groups and networks the
of the workplace and where possible during normal organization can allow those for whom the group is
work hours to provide access to employees with various being established to be consulted in identifying the
personal circumstances. need or needs to be addressed.

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Organizations should support the effectiveness of Organizations should be equally supportive of all such
support groups and networks by: groups to avoid any accusation of bias or risk alienating
a) maintaining a clear purpose and role that relates those who do not identify with a specific group, or any
to the organization’s vision for diversity, equity group at all.
and inclusion; NOTE 3 Groups with only a few members might need
b) offering financial and administrative support to wider support or resource to be able to perform the
the launch and maintain on-going development same role as groups with more members.
of the group(s);
Participation in employee groups should be based upon
c) offering training and development to those
individuals volunteering or self-electing to become
co-ordinating, leading or chairing group(s);
involved rather than being selected or nominated by
NOTE 1 Training such as negotiation skills or managers or business leaders, unless nomination is as
conflict management could be helpful if facilitating a result of election or selection by peer groups.
discussions involving emotions and differing
personal perspectives and experiences.
d) making it clear that employees have the right to
attend such groups and networks, and that their
managers should support them in doing so (if
groups meet during work time);
e) requiring that they remain part of the wider
organization and are inclusive and open to all;
f) agreeing the scope, role and activities of the group
and the mandate that the group holds.
NOTE 2 For example, whether they are permitted
to speak to the media on behalf of the group and/
or the organization.
g) requiring that group members engage with wider
improvement initiatives relating to diversity, equity
and inclusion, so that a wide range of diverse
perspectives contribute to work in these areas;
h) requiring feedback from each group, outlining how
their activities have supported the organization’s
ambitions around diversity, equity and inclusion;
i) providing feedback and recommendations for
changes to the organization’s existing policies,
practices and processes to better support diversity,
equity and inclusion; and
j) allowing or enabling recommendations made by
such groups to be communicated, reviewed and
actioned, for example by a diversity, equity and
inclusion committee or employee council.

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6 Assessing the impact of diversity, equity and inclusion

on organizational performance

6.1 General principles Organizations that develop, use or invest in

technology should take into account the impact of a
COMMENTARY ON 6.1 lack of diversity, equity and inclusion in the product
Organizations are advised to assess the impact of conception, development and testing stages.
adopting a façade of supporting diversity, equity and
inclusion because it believes that is what is expected 6.2.2 How technology can impact diversity, equity and
of it (a practice referred to as a “badging exercise” or inclusion in the workplace
“purpose washing”) and the damage that a lack of Organizations should assess the types of technology used
authenticity could have on its reputation or brand. within the workplace and its impact and influence on
When conducting an impact assessment, organizations different social, cultural and underrepresented groups.
may find it helpful to refer to the mapping exercise in
4.1. as a starting point. Organizations should make all employees aware of
available technology and the way in which it can help
NOTE Internal stakeholders may include:
them to address any concerns which are a barrier to
• employees and employee representative groups; inclusion for:
• shareholders and investors; a) employees who are less comfortable with
• talent acquisition and retention; and technology and less willing to apply for roles
• product development technology and innovation. which they believe require a greater reliance of
technology or technical skills;
External stakeholders may include:
b) economic or educational backgrounds that mean
• consumer and customer engagement;
some employees are less familiar with some forms
• suppliers and providers; of technology and equally less willing to apply for
• communities; and roles where technical skills may be needed;
• new markets. c) the use of assistive technology to support those
with conditions, such as text to voice applications
Diversity, equity and inclusion impact internal and or subtitling software; or providing digital
external stakeholders, and organizations should be able accessibility to those on lower incomes or limited
to demonstrate that this has been taken into account data connectivity; and
when assessing organizational performance.
d) employees limited in their use of technology due
to medical or other conditions.

6.2 Technology Organizations should assess the different forms of

COMMENTARY ON 6.2 communication used in the workplace and its impact
on different groups of employees.
Whilst 6.2 focuses on technology, the principles apply
to all forms of product development and design, both NOTE 1 Whilst remote and distance working can
technical and non-technical. support greater diversity and equity by providing
opportunities to a larger pool of employees, without
6.2.1 General principles regular social interaction, it can also lead to a sense of
Organizations should take into account both the isolation, exclusion and a feeling of being left out or
positive and the negative impact of technology on an outsider.
internal and external stakeholders when developing Examples of communication technology include:
a diversity, equity and inclusion strategy. • generational preferences for communication, such
as instant messaging or text style communications
Organizations should take into account how:
instead of face-to-face;
a) technology can impact diversity, equity and
inclusion in the workplace;
b) technology can remove barriers and support
accessibility; and
c) diversity, equity and inclusion can impact new and
emerging technology.

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• internal and inter-office communication tools and Any applications designed to emulate human thought
applications, such as Skype, Slack, Google Hangouts, processes and behaviours, including but not limited
Yammer, etc; to Artificial Intelligence (A.I.), sentient and predictive
• use of remote/interactive communication, such as technology and biometrics such as facial recognition,
video-conferencing; and should be developed in a manner which eliminates any
specific character and personality traits or biases, unless
• websites and digital applications that support
recognition of a specific characteristic or trait is a key or
accessibility or software that supports accessibility,
necessary aspect of the application.
such as text to audio or multi-language options.
NOTE 2 Not all employees are familiar with slang Where programmes are developed with specific user
or casual terms due to generational, cultural or groups in mind, organizations should include end user
geographical differences. groups in the development cycle from the outset.
NOTE 3 Some employees might be less comfortable or
more self-conscious when using applications such as 6.2.3.2 Development of products and services
video-conferencing so it is advised also make audio-only Organizations should assess how the use of a product
options available. or service is impacted by:
NOTE 4 Organizations can consider ways in which they a) physical ability;
can bring individuals who work remotely together b) cognitive ability;
through things such as regular team meetings in a
c) neurodivergence;
physical location where it is possible or appropriate, team
catch-ups and updates or the use of video-conferencing d) physical environment;
and instant messaging tools to support continuous e) language and culture;
engagement and inclusion with other team members f) accessibility (physical and/or psychological); and
and managers. g) social, political and environmental attitudes, views
6.2.3 How diversity, equity and inclusion can impact and values.
new and emerging technology NOTE 1 An example of non-inclusive product design
is where something designed by a right-handed user
6.2.3.1 Machine learning and Artificial Intelligence (A.I.) does not create the same experience or result for
COMMENTARY ON 6.2.3.1 left-handed users.
Machine learning and A.I. are applications designed by NOTE 2 By including the principles of diversity,
humans to replicate the way humans think and react equity and inclusion at every stage of the product
when presented with specific information. Unless the development cycle, organizations are better able
A.I. development process has checks and balances in to create products which can be used by the widest
place to check for and to prevent unconscious and possible range of users.
conscious bias, the final programme or application
could be an extension of or include elements of the
programmer/developer’s bias. Failure to carry out these
checks can mean that an application which has been
designed to be used in a number of different situations
and circumstances might only produce expected results
in some situations and circumstances.
For example, if an employer regularly selected younger
candidates after screening candidates using A.I. the
applications might “learn” that younger candidates
are more desirable than older candidates. It can then
add age as a component to its screening process and
eliminate older candidates. If A.I. is taught through
data on existing and past employees in a workforce
predominantly composed of a particular ethnicity, then
A.I. might learn bias against candidates with different
ethnicities, or during interviewing that a candidate’s
slow or slurred speech or atypical facial expression(s)
do not conform to previous candidates and screen out
otherwise qualified candidates with neurodivergence
or disability.

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7 Engaging and supporting underrepresented groups

COMMENTARY ON CLAUSE 7 • actions and behaviour on the part of existing

The key to an effective diversity, equity and inclusion employees which is designed to cause the new
strategy is the ability to engage, retain and develop appointee to fail or to make them feel uncomfortable
employees and customers from a wide range of social or excluded;
and cultural groups, including underrepresented groups. • the newcomer becoming isolated and unsupported; and
An organization’s reputation and public perception might • encourage the formation of employee resource
influence how it engages with underrepresented groups. groups (ERG) to drive the conversation around
When seeking to engage underrepresented groups, diversity, equity and inclusion.
organizations are advised to take a realistic approach
based upon prevailing social and cultural norms and 7.1 Engaging underrepresented groups
customs which might prevent some groups from
In addition to the recommendations in 5.4,
engaging with them.
organizations looking to engage with specific groups
Where an organization is unable or unsuccessful in should also take into account the following as a means
engaging effectively with a particular group, they of engagement:
can consider engaging with organizations that already
a) public meetings;
have a relationship with the group and who may be
able to act as an intermediary or support and assist in b) roadshows and focus groups;
other ways. c) individual workforce activity;
For example, if an organization operates in a sector NOTE 1 For example, charity fundraising or
which is not considered to be acceptable to a particular volunteering days.
social or cultural group, such as alcohol or gambling, d) publications, leaflets and letters;
attempting to engage with individuals from that
e) open days, exhibitions and drop-in sessions;
group might be met with limited success. Where a
group is unwilling to engage for reasons of religion, f) surveys and questionnaires;
on-going efforts to engage could be perceived as NOTE 2 For example, online, text or by post.
insulting or offensive. g) social media opportunities;
Quota systems and positive discrimination or action h) site or place visits;
used to increase levels of underrepresented groups in
NOTE 3 For example, schools or colleges to
a homogenous group with little or no diversity can be
promote careers.
met with a challenge and the false perception that an
individual might be appointed in order to meet targets. i) charities and community groups; and

To prevent this, it is important to clearly communicate j) specialist recruitment agencies.

that these systems are a means of increasing
participation of protected groups from a pool of In the case of customer engagement, organizations
equally qualified candidates, and take appropriate should offer, when deemed appropriate:
action to prevent: 1) free giveaways;
• low morale, lack of motivation and departure of 2) customer events, reviews and endorsements;
employees who also applied but were unsuccessful by 3) user group testing and feedback;
providing constructive feedback; 4) reimbursing people’s time for contributing;
• resentment, negativity and unspoken refusal to 5) loyalty and rewards programmes; and
properly support the appointee because they are
6) branding or marketing.
perceived as an outsider;

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7.2 Supporting underrepresented groups

COMMENTARY ON 7.2
Individuals appointed as a result of a quota
requirement or positive/affirmative action might
become the focus of resentment from others in the
team or organization.
This resentment could take the form of both passive
and active actions and range from doing nothing such
as withdrawing or failing to provide basic support
or assistance provided automatically to others and
an unwillingness to engage or communicate unless
required to do so; to actively conspiring to cause issues
and problems, such as failing to pass on information
or invites to meetings, or behaviours designed to
undermine, exclude or isolate.

Where organizations have chosen to implement

quota-based systems and positive discrimination
or action for protected groups, they should also
implement a framework for ongoing support and
assistance in addition to the recommendations in 5.4.
NOTE This includes training and awareness as to why
the organization has chosen to take this approach
to address any potential areas of conflict, dissent or
negativity before implementing and thereafter on
an ongoing basis as required.

Organizations should provide such employees with

a buddy or mentor either inside or outside of the
organization to identify such incidents and provide
support in addressing them.

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8 Implementing the concept of “diversity of thought”

and “intercultural competence”

8.1 Diversity of thought Organizations should include diversity of thought

within their overall strategy and take steps to
COMMENTARY ON 8.1 encourage and support its adoption throughout
Innovation and development depend on the ability the organization.
of individuals within a group to think differently from
one another. Organizations should provide guidance as to how
The ability of a group to see something from different views and opinions should be shared in a manner
sides, angles, and perspectives, especially where the that is respectful and encourages understanding and
difference relates to people who identify with different constructive progress and without causing offence,
social, cultural, or other underrepresented groups, is ridicule, or disparagement.
improved when groups have greater diversity.
When attempting to identify with other perspectives, 8.2 Intercultural competence
empathy, placing oneself in someone else’s shoes
COMMENTARY ON 8.2
and imagining their experience, is not the same as
experience. For example, a man can empathize with Culture is defined and influenced by many things,
the pain of childbirth because he knows, understands either individually or in combination with one or
and can relate to the experiences relating to physical more factors.
pain, but this is not the same as actually experiencing Intercultural competence is the ability to
childbirth. The man is imagining what it would be like understand cultural and social differences and adapt
based on his idea of a similar experience. communication and actions accordingly.
Diversity of thought can be achieved through an Competent intercultural communication includes
organizational strategy that actively encourages, language, tone, actions, behaviour and conduct that
promotes and supports diversity, equity and inclusion. is appropriate to the expectations of the social or
cultural group, the circumstances, the situation, and
Organizations should encourage individuals to: the relationship between the parties involved.
a) embrace, champion and celebrate difference; Examples of intercultural incompetence or insensitivity
b) respectfully share conflicting and contrasting views might include the use of a specific word or term
that support positive progress; without understanding its impact within the context
of a specific culture, the use of a religious symbol as
c) see difference as a route to innovation and success;
a fashion accessory, or gestures and behaviours which
d) ask difficult questions that provoke thought and might be acceptable to one group but not another.
challenge existing views and opinions that allow
A lack of intercultural competence can result in
individuals to learn from each other;
an organization acting in a manner that could be
e) reward honesty and openness that supports considered as insensitive, inappropriate, offensive,
positive and constructive progression; insulting, lacking awareness or misappropriation of a
f) introduce new perspectives and different ways trait or characteristic specific to, or widely accepted as
of thinking; being associated with a cultural or social group.
g) consider the impact of social and cultural This is viewed as offensive or insulting because the
history and its current impact on society and the culture of origin rarely receives the same support
workplace; and or praise for this characteristic or trait as those who
h) review past actions and decisions and take misappropriate it.
appropriate positive action.

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Cultural misappropriation is adopting or copying a

characteristic, trait or manner of speaking most commonly
associated with a different social or cultural group.
Cultural misrepresentations, which may be based on
outdated or inaccurate views and opinions, or a lack of
knowledge or understanding, might be perceived as a
micro-aggression.
Microaggressions occur on a systemic level; for example,
unequal pay or benefits, treatment or conditions based on
traits or characteristics such as age, gender or ethnicity.

Organizations should take into account the ways and

areas in which a lack of cultural competence impacts
them, including but not limited to:
a) product development;
b) marketing and advertising;
c) sponsoring events or individuals;
d) take up of products and services;
e) brand ambassadors and spokespeople;
f) press statements and social media posts;
g) humour or jokes in the workplace; and
h) employee conduct and behaviour away from
the workplace.

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9 Measuring progress and developing a strategy for

continuous improvement

9.1 General principles n) monitoring career progression of under-represented

groups;
Organizations should have a mechanism in place for
o) relationship between diversity and overall
measuring progress and a strategy for continuous
commercial performance and profit/loss.
improvement.

NOTE 2 Annex A and Annex D give examples of

Before agreeing targets, indicators and measures of
self-assessment and employee questionnaires.
performance, organizations should:
a) establish who is responsible for the execution and
success of the diversity strategy (see Clause 4.2); 9.3 Continuous improvement
b) agree a process that is transparent and supports Organizations should have a strategy in place for
accountability; continuous improvement.
c) establish current/existing levels of diversity, equity
and inclusion in the organization and the data and Targets for continuous improvement should be based
information required to measure progress; upon the needs of the organization in the short-,
mid- and long-term and in accordance with their
d) designate the individual or team responsible for
usual operating needs and requirements to minimize
measuring and reporting on progress; and
disruption to the organization.
e) agree how progress is to be tracked and measured.
Targets should take into account factors which have
9.2 Measuring progress an impact on the organization, including but not
limited to:
Organizations should measure the success of their
a) organization size and future growth plans;
diversity, equity and inclusion strategy in other areas
such as employee demographics, external stakeholders b) location and demographics of available workforce;
and commercial performance. c) employee turnover and attrition rates;
NOTE 1 Recommendations for monitoring and auditing d) organization type and attractiveness to
internal policies, processes and procedures are included potential employees;
in 5.2 and 5.3. e) sector or industry and attractiveness to
potential employees;
Method(s) of measuring progress should include:
f) types of roles available and appeal to
a) analysis of customer demographics; potential employees;
b) audit conducted by accredited external auditor; g) market expansion and new jurisdictions;
c) audit conducted by the internal audit function; h) product development, research and development
d) awards and recognition; (R&D) strategy and innovation;
e) benchmarking surveys; i) investor relations and corporate social
f) customer acquisition, retention and revenue; responsibility;
g) employee acquisition and retention statistics; j) strategic partnerships, mergers and acquisitions;
h) employee demographic statistics; k) generational trends and changes in social attitudes
and customs; and
i) employee posts and ratings on employer review
sites; l) benchmarking continuous improvement.
j) gender and ethnicity pay gap reports;
While there are a number of ways in which
k) impact of sponsoring and supporting events; organizations can measure progress, the method used
l) innovation and product development as linked to should be based upon a clear and objective set of
diversity; and measures or metrics that allow the organization to
m) levels of brand recognition, association and see what changes have taken place and the reason for
awareness; those changes.

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Annex A (informative)
Self-assessment and strategy

A.1 General
Before developing a strategy and a set of objectives an organization is advised to conduct an initial evaluation and
basic benchmarking exercise.

The self assessment questionnaire (Table A.1) is a tool intended to help an organization start thinking about what
diversity and inclusion means to them, what it looks like in their organization and how it applies to them.

It can be used to identify what an organization does, what it does not do, where it could do more, and apply
timescales and develop an action plan for implementation, assessment and review.

This will help an organization understand where it is now, identify any immediate opportunities and challenges,
the costs associated with such opportunities and challenges and then develop a strategy and set of objectives that
are clear, achievable and measurable.

Organizations may use the template below to conduct an initial evaluation.

Table A.1 – Self-assessment questionnaire

Area Description Considerations

Organization

Purpose and scope What is the purpose and • If the organization is a producer of products
scope of the organization? and services, is there a potential to make these
more inclusive? If the product or service is
intended for specific social or cultural group
does it require specific knowledge of that
group or groups, and if so are they represented
within the organization?
• Does the organization operate in a sector or
industry, or engage in activities, which may not
be acceptable to all social or cultural groups?

Operating environment What environment does the • What pre-existing laws, regulations or religious,
organization operate in and social or cultural customs and practice are
how could this impact on there that the organization needs to take into
any diversity, equity and consideration?
inclusion strategy? • How does geographical location have an impact
upon the types of individuals it might attract?
• Is the environment inclusive and accessible
to all; for example, wheelchair access, ear
defenders, prayer room or provision of support
for individual needs relating to conditions or
neurodiversity?

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Table A.1 – Self-assessment questionnaire (continued)

Area Description Considerations

People

Benchmarking3) Has the organization • Does the organization hold basic demographic
conducted initial information such as the ratio of male to female
benchmarking to assess employees, ethnicity, age, disabilities and other
current levels of measurable key characteristics or traits?
diversity and established a • How does this information relate to things such
starting point? as salary, roles, location or opportunities in the
organization?

Underrepresented groups Are there trends and patterns • Has the benchmarking highlighted trends and
which indicate low levels of patterns which indicate low levels of diversity
diversity in some teams or in some teams, or that whilst levels of diversity
levels in the organization? within the organization are acceptable overall,
the levels of diversity within senior teams
are low?
• Are underrepresented groups encouraged to
provide open and honest feedback as a means
of identifying challenges/barriers to increased
levels of diversity and ways to address them?

Key stakeholders Who are the organization’s • Who are the individuals responsible for
key stakeholders that need to developing and implementing the strategy and
be involved in developing the do they have the knowledge, skills training and
organization’s strategy and support within the organization to be able to
setting its objectives? do this?

Environment

Location Where are the organization’s • Is the organization or its operations located in
operations and workplaces places that are easy to get to and if not does it
located and how easy is it for provide transport for individuals who cannot
all stakeholders (employees, travel there?
customers, suppliers/ • Are there concerns relating to personal safety
providers) to access them? for some groups of employees, such as female
employees coming to or leaving work during
the evening?

Physical access Is it possible for all employees • Does the physical environment restrict access
to access all areas of the to some areas of the workplace for some
workplace? individuals or groups?

Environment Are there private areas • Are there private areas within the workplace
within the workplace environment to support physical, social, or
environment to support cultural needs such as prayer rooms, gender
social or cultural needs? segregated areas in some global locations, areas
where employees can attend to personal needs
such as weaning mothers pumping breastmilk,
or attending to medical or other conditions
in private?

3)
Basic benchmarking is statistical and relates to the demographic breakdown of the individuals in the organization.

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Table A.1 – Self-assessment questionnaire (continued)

Area Description Considerations

Communication

Communication Are there any barriers to • Has the organization identified any language
effective communication, such barriers and if so, how will these be addressed,
as language? for example the use of translators or
How could this impact the interpreters?
effectiveness of any diversity, • Will all information be provided using a
equity and inclusion strategy? number of different media formats so that it is
How will communication accessible to individuals with visual or hearing
strategies support invitations conditions?
with visual and hearing • How does the organization support individuals
conditions? with oral conditions?

Intercultural competence Has the organization • Are those responsible for communication
evaluated the intercultural (internal and external) aware of the concept of
competence of intercultural competence?
those responsible for
communication, and the
risks of communication
which could be perceived as
interculturally incompetent
or insensitive?
What support will be
provided to improve
intercultural competence?

Impact assessment

Challenges and barriers What are the challenges • Before starting to develop a strategy and set
and barriers to an effective of objectives, organizations are encouraged to
diversity, equity and inclusion clearly and objectively identify the challenges
strategy? and barriers – some of which will be outside of
What are the impacts of these its control.
challenges and barriers?

Goals and objectives Has the organization • Are goals and objectives realistic and
identified and agreed a set achievable?
of clear goals and objectives • Does each goal have an owner, a clear action
to support its diversity, equity plan, and implementation date?
and inclusion strategy?
• Can the goals and objectives be measured
to assess effectiveness and impact on the
organization?

Cost What is the estimated cost • Have organizations objectively evaluated the
of implementing the costs of implementing the strategy?
proposed strategy? • Does this cost include training, changes to the
physical environment, operating practices,
hours and mechanisms for additional support
such as transport, etc.?

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Table A.1 – Self-assessment questionnaire (continued)

Area Description Considerations

Implementation

Action plan Once the organization agrees • All goals and targets do not need to be met at
upon an action plan, consider the same time. Organizations can consider a
the following for each goal or phased approach based upon short-, medium-
objective: and long-term goals.
• What is the goal or • Have periodic reviews of the strategy
objective(s)? against the action plan been scheduled to
• Why is it relevant to the monitor progress?
strategy? • Does the action plan allow for and
• Who is responsible for the accommodate any changes to the organization,
goal or objective? people or environment?
• How will the goal or
objective be met?
• When will the goal or
objective be actioned?
• How will the organization
measure the success of the
goal or objective?

Monitoring and Has a mechanism for Examples of monitoring and assessment against
assessment monitoring and assessing targets might include the following.
progress against the action • If the aim is to have 50% women in a team by
plan and against the a particular target date the organization can
organization’s strategy and monitor progress at agreed points to check
aims and objectives been the plan is on track. If there is no change
established? from one point to the next, the organization
This can be done by the key can review the strategy to understand where
stakeholders, a designated improvements need to be made and reassess
individual or an existing the aim and the target date as appropriate.
function in the organization • If the organization includes diversity related
such as an internal audit or targets in its employee bonus or incentive
risk team. programmes, the organization can monitor pay-
Where monitoring and out and conduct a review to establish whether
assessment indicates that meeting targets has resulted in a decrease in
the aims or the targets are the quality of appointments, performance or
unrealistic, the organization had an impact in any other areas.
can establish why, and then
reassess and re-issue the
action plan accordingly.

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A.2 Five-step plan

Organizations may use a simple five-step plan to help identify and organize actions, an example of which is given
in Table A.2.

Organizations are encouraged to start with high level actions and activities that are realistic and achievable.

Once completed they can then add in additional more detailed activities and actions for future versions.

For example, for an organization just starting on the journey, commitment might not include the whole
organization, it might just be the HR or people management function and the first action might be a diversity policy.

Once completed, additional actions might be the production of new policies that sit below the diversity policy
targeting specific areas such as flexible or remote working, dignity at work or recruitment policy.

These policies might also lead to additional activities and actions. For example, the recruitment policy might
have a number of individual tasks such as developing guidelines for how roles are advertised, engagement of
recruitment partners, positive or affirmative action, applicant screening, induction policy and so forth.

Table A.2 – Example of a simple five step plan

1. Commitment • Secure the engagement and support of the right individuals in the organization or
leadership team(s).
• Not everyone will be supportive, so it is important to identify the individuals who can
influence others or who are able to provide practical support at other levels.
• Examples of individuals who can help influence or provide support include non-executive
directors and board members, HR and people leaders, employee representatives, team and
divisional managers, external stakeholders.

2. Action • Agree action points.

• Actions should be realistic, achievable and appropriate to the organization. Each action
should have clear answers to the questions: What? Why? Who? How? When?
• Examples of actions might include producing a diversity and inclusion policy hiring
individuals from underrepresented groups, auditing existing practices, targeted training,
establishing employee support groups, etc.

3. Responsibility • Assign clear roles and responsibilities to individual(s) and team(s) responsible for delivery.
• This could be collective responsibility, such as the Board or senior team, or a committee,
specific individuals (DEI lead, team leaders and managers), or a combination.
• Defined roles and include responsibilities for communication, resourcing, training,
support, evaluating and providing updates on progress.

4. Measure • Tracking progress confirms that agreed actions are being implemented.
• Effective measurement needs a starting point and an end point: What do things look like
now vs what do we want them to look like?
• Tracking progress helps to identify any challenges or barriers, such as low numbers of
applications for specific roles or resistance from stakeholders, as well as understanding
what is working well.

5. Success • What does success look like?

• It is important to acknowledge success. Success could be completing all of the agreed
actions, or it could be completing each individual action in its own right, such as
completing awareness training, receiving more application forms, hiring someone from an
underrepresented group, the completion of an audit or the impact of DEI on revenue.
• Success can be acknowledged in many ways, from congratulatory communications and
public recognition to celebratory events, financial or non- financial team or individual
rewards, such as performance bonuses.
• Acknowledging success supports motivation, engagement and commitment.

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Annex B (informative)
Workplace toolkit

B.1 Self-assessment questionnaire (SAQ)

Organizations can use the self-assessment questionnaire template in Table B.1 to:
• help create a new strategy or assess the effectiveness of an existing strategy;
• identify gaps, challenges and address areas of improvement;
• monitor and assess the effectiveness of their policies and practices;
• develop tools to assess the impact of the strategy on workplace culture and environment;
• measure progress against the strategy and stated aims and objectives;
• support continuous evolution, development and improvement by adding new or expanding on existing
requirements; and
• track year-on-year progress by conducting an annual assessment of the diversity, equity and inclusion strategy.

The questionnaire in Table B.1 can also be used to develop a more detailed internal audit document or
incorporated into existing audit documents.

Table B.1 – Action plan template

Recommendation Considerations Action

A. Organization commitment to diversity, equity and inclusion

Diversity, equity and Does the organization have a committee, board (or e.g. Add DEI as an
inclusion committee, similar) whose role is to define the organization’s agenda item to next
board or similar diversity, equity and inclusion strategy and objectives? board meeting

Diversity, equity and Does the organization have a high-level policy statement
inclusion policy outlining its commitment to diversity, equity and inclusion?

Strategy, objectives and Does the organization have a clearly defined strategy,
action-plan objectives and action plan for implementing diversity,
equity and inclusion?

Challenges Has the organization identified challenges to the

successful implementation of its strategy or objectives?
NOTE 1 Challenges might be local laws and regulations,
geographical location or religious, social or cultural
practices, an existing workplace culture or environment
which is resistant to change, or where changes to practices
and levels of diversity will take longer due to operational
constraints such as time required to complete training.

Owners and key Has the organization identified the owners and key
stakeholders stakeholders who will help the organization meet its
strategic objectives?
Has the organization identified or engaged in partnerships
with external local, national and international
organizations that support diversity, equity and inclusion?

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Table B.1 – Action plan template (continued)

Recommendation Considerations Action

Communication Has the organization communicated its objectives to

owners and key stakeholders and allocated roles and
responsibilities for development and implementation of
the strategy?

Measurement and How will the organization measure and assess the
assessment successful implementation of its strategy and specific
objectives and targets

B. Policies, processes, practices and procedures

Policies What policies does the organization have in place to

support diversity, equity and inclusion?
Who is responsible for maintaining and updating the
policy (policy owner)?

Process What process does the organization have in place

to verify that policies are effectively communicated
throughout the organization?
NOTE 2 For example:
• Does the organization have a staff or employee
handbook which is issued to everyone?
• Does the organization make new starters aware of its
commitment to diversity, equity and inclusion as part of
its induction and new starter process?
• Does everyone in the organization comply with the
recruitment and selection process or do some teams
apply a different approach?
• Is there a process for ensuring that all individuals
responsible for recruitment and selection have received
appropriate training including interview skills and
bias training?

Practices and How does the organization monitor that practices and
procedures procedures are applied consistently across all applicable
teams/functions in practice?
NOTE 3 For example:
• Are there job descriptions for everyone in the
organization and are they reviewed and updated to
remain relevant?
• Do all teams apply blind screening to the
applicant process?

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Table B.1 – Action plan template (continued)

Recommendation Considerations Action

Monitoring and How does the organization measure the monitor and
assessment assess the effectiveness of its policies, processes, practices
and procedures?
NOTE 4 For example:
• If the organization offers flexible working but there
is no record of anyone making a request for flexible
working, or requests from a particular team or
department are noticeably lower, does the organization
investigate to understand the reason for this?
• If after implementing changes to the recruitment
strategy, there are noticeable differences in levels of
diversity across different teams/functions, does the
organization investigate to understand why?

Review Does the organization have a process for reviewing its

policies, processes, practices and procedures?
NOTE 5 For example, organizations may conduct reviews
on an annual basis as standard, based upon changes to
laws and regulations, based upon the recommendations
or findings of an external auditor, or based upon its own
internal monitoring and assessment evaluations.

C. Training and development

Training – role based What training does the organization provide and who is
it available to?
NOTE 6 For example, is training provided only on a
per role basis (technical or IT training is only available
to those working in that area) or to specific groups of
employees (external academic courses are only available
to senior employees) or are opportunities also made
available to others?

Training – diversity and Does the organization provide specific training to support
inclusion diversity, equity and inclusion?
NOTE 7 For example:
• Are all individuals or individuals with specific roles or
areas of responsibility required to attend or offered the
opportunity to attend training relating to conscious and
unconscious bias or intercultural competence?
• Where individuals are required to conduct interviews,
assessments, reviews or appraisals, are they provided
with specific training and tools relating to equity.
This can include compensating measures and making
allowances for differences between candidates, such as
allowing an applicant with dyslexia or visual condition
additional time or support, or allowing a candidate
with aural or oral condition the opportunity to respond
in writing?

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Table B.1 – Action plan template (continued)

Recommendation Considerations Action

Development Does the organization conduct personal performance

reviews (appraisals) and support diversity, equity
and inclusion?
NOTE 8 For example:
• Are individuals from underrepresented groups
encouraged to consider applying for roles within the
organization or provided with additional training to
support career progression?
• Does the organization have a fast-track system for
underrepresented groups and what is the impact of
this programme on individuals who are excluded
from applying?

Monitoring and How does the organization monitor and assess the
assessment effectiveness of its training and development strategy?
NOTE 9 For example:
• Does the evidence show a year-on-year change in
the levels of underrepresented groups within the
organization or of those being promoted?
• What impact has this had on the organization and
has this been positive, negative or neutral? (Positive
could be that the organization is now able to engage
with new customers or suppliers, negative could be
that individuals from non-underrepresented groups
have departed due to a lack or career progression, and
neutral could be no obvious change or impact).

D. Culture and Environment

Culture Does the organization promote a culture and

environment that supports diversity, equity and inclusion?
NOTE 10 For example:
• Is the message of diversity, equity and inclusion
actively promoted and supported by the leaders of
the organization? This could be in a number of ways,
including but not limited to, internal and external
statements, supporting or sponsoring events, taking
part in initiatives and programmes, or promoting itself
as an organization that supports diversity, equity
and inclusion.
• Are successes and achievements relating to diversity,
equity and inclusion recognized?
• Are teams and individuals encouraged to think
differently and see difference as a positive advantage
(diversity of thought)?
• Is integration and acceptance of underrepresented
groups supported through social, sports or other events
and initiatives which encourage employees to come
together as equals?

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Table B.1 – Action plan template (continued)

Recommendation Considerations Action

Environment Does the organization promote an environment that

supports diversity, equity and inclusion?
NOTE 11 For example:
• Is additional support provided for underrepresented
social and cultural groups? This could be in the form of
access to internal or external support groups, resources
and training, adaptions to the workplace and working
practices.
• Are different departments, teams and individuals
encouraged to work together as teams rather than
individual functions?
• Are there common areas such as a staff canteen or
chill-out area where employees from different teams
can spend time together and interact?

E. Measuring Progress

Policies and practices Does the organization have a framework for monitoring,
assessing and reviewing the effectiveness of its diversity,
equity and inclusion policies and practices?
NOTE 12 For example:
• Have changes to policies and practices supported
the organization’s aims and objectives and helped
achieve targets?
• Are employees aware of the organization’s policies?
This can be measured by looking at how many have
enquired about them or raised an issue as a result
of them.
• Has there been an increase in the number of
applications from underrepresented social or
cultural groups?
• Have DEI policies, or changes to DEI policies, impacted
employee retention?

Workplace culture Does the organization have a framework for monitoring,

assessing, reviewing and measuring the workplace culture?
NOTE 13 For example:
• How many employees use common and shared spaces
and is there visible integration and interaction?
• Is there an employee survey which asks respondents
to share their views on the organization’s approach to
diversity, equity and inclusion?
• Are workplace review websites and social media sites
monitored to assess how current and past employees
view the organization?
• Are social and other initiatives well attended
and supported?

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Table B.1 – Action plan template (continued)

Recommendation Considerations Action

Other Does the organization monitor and measure the

effectiveness of its diversity, equity and inclusion strategy
outside of the organization?
NOTE 14 For example:
• Is diversity, equity and inclusion included in the
organization’s annual report?
• Does the organization support, sponsor, attend or speak
at diversity, equity and inclusion events?
• Is the organization part of any diversity, equity and
inclusion initiatives and programmes?
• Has the organization won an award or been recognized
as a leader in diversity, equity and inclusion?

Tracking progress Does the organization track progress to support

continuous improvement and against the overall strategy
and aims and objectives?
NOTE 15 For example:
• Is there statistical information measuring the levels of
diversity in the organization and is this information
recorded at the same time and in the same way every
year to allow for year-on-year comparison?
• Are changes to policies and practices recorded and the
impact of the change monitored?
• Is there an annual progress report which provides an
update on how the organization is performing against
the diversity, equity and inclusion strategy and the aims
and objectives?
• Is there a framework for reviewing the organization’s
strategy on an annual basis to assess progress against
stated aims and objectives?
• Is there a framework for assessing the impact of
diversity on the performance of the organization and
teams within the organization?
• Is the organization’s progress shared with internal and
external stakeholders?

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Annex C (informative)
Role play and interactive exercises

C.1 General C.3 Exercise 2: Accessibility

There are a number of simple roleplay and interactive Props needed: blindfold, earplugs, wheelchair, other
exercises organizations can include in their internal props to help explore visible and non-visible conditions,
processes and existing training and awareness such as restricting movement, or altered documents to
programmes to help support diversity, equity replicate the experience of dyslexia or colour-blindness.
and inclusion.
Steps:
C.2 Exercise 1: Stakeholders a) Ask able-bodied employees to spend a working
week as an impaired employee or customer using
Props needed: images of a diverse range of people. the props provided.

Steps: b) No change to their normal routine is made.

a) Give each team member a selection of newspapers, c) A daily video or audio diary of their experiences
magazines or similar and ask each to select five is created.
different images of people they think best look d) The experiences and diary then form the basis
like their past, current and future stakeholders of a feedback session to the appropriate team
(stakeholders could be customers, employees, for example experiences navigating premises,
stakeholders, investors based on the context of accessing or using products.
the exercise). NOTE It is advised that feedback includes both physical
b) Bring the team together and ask each member to and emotional experiences.
explain their reasons for the images they selected.
C.4 Exercise 3: Bias
Discussion points:
Props needed: sample of job applications or customer
1) Why did different people choose or not chose
queries with all personally identifiable data such as
different types of stakeholders?
name, address, age and email address removed; a wide
NOTE 1 Consider biases and blind spots. selection of images showing different people from
2) How have stakeholders changed from past to different social and cultural groups.
future and in what ways does this impact the
organization? Steps:
NOTE 2 Consider changing stakeholders’ a) Give each delegate a copy of the application or
demographics, locations, culture and social impacts. query. Based on the information ask them to build
3) Does the make-up of people in the organization an image of the sender.
look like the organization’s stakeholders (internal b) Give them five minutes to consider the information
and external) and how does this impact the and then ask them to select an image that they
organization (both positive and negative)? think best represents the sender.
NOTE 3 Consider impact of not understanding or
meeting needs of future stakeholders. Discussion points:
1) Everyone has biases (positive or negative).
2) Biases are related to personal and past experience.
3) Everyone may interpret information differently.
4) Human instinct is to try to fill in gaps where
information is missing or incomplete.
5) Visualization, perception and assumption plays a
key part in decision making.

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Annex D (informative)
Sample stakeholder surveys

COMMENTARY ON ANNEX D Most common role types/categories are listed below:

Employee surveys can include questions relating to • executive board (an executive board has active
employee satisfaction levels with the role and the management responsibilities);
way in which they are managed, their commitment • non-executive board (a non-executive board is a
to the organization or belief in the organization’s board without responsibilities for daily management
stated aims and objectives. Responses may be analysed or operations of the company or organization);
to understand overall responses but also any trends
• data (including analytics, insight and strategy but not
relating to specific cultural, social or other employee
database admin);
demographic group. This annex contains sample
questions that organizations can use in surveys • design and creative (including digital, non-digital
designed to benchmark and measure diversity, equity and web);
and inclusion from both an organization and employee • marketing (including advertising, affiliates, search
perspective. engine optimization, customer relationship
Organizations may also choose to adapt and use the management, VIP and loyalty);
sample questions shown below to create surveys for • media (including PR and media relations);
other stakeholders such as customers or external • sales and business development;
suppliers and providers. These questions have been
• product development and innovation;
taken from the All-Index® survey 4).
• trading and markets (odds compilers, risk/liability
Organization survey sample questions management);
Sample questions include the following. • finance, accounting and budgetary control;
• How many locations does the organization have • operations (including customer support, payments,
nationally or internationally? fraud/security and responsible gambling);
• Where are the employees located? • human resources (including recruitment, people
• How many employees does the organization have? management, learning and development, corporate
social responsibility and diversity and inclusion);
Understanding levels of demographic diversity • technical (including network and infrastructure, sys
The following questions can be asked to assess levels admin, hardware/software development and testing/
of gender or other forms of diversity by asking quality assurance);
participants to report on numbers of employees in • legal and regulatory compliance; and
relation to different groups, such as gender, age,
• hospitality (including food and beverage, front of
ethnicity, and so on, based on age, role or type of role.
house, service/janitorial).
• How many employees are male/female?
• Does the organization record any of the following Salary ranges
employee demographic information such as gender, Typical salary ranges cover the:
age, ethnicity, religion, and so forth? • number of employees earning: UNDER 25,000;
• Please indicate the number of employees identifying • number of employees earning: 25,000 – 49,999;
as a member of a social or cultural group based
• number of employees earning: 50,000 – 74,999;
on role.
• number of employees earning: 75,000 – 99,999;
• number of employees earning: 100,000 – 149,999;
• number of employees earning: 150,000 – 199,999; and
• number of employees earning: 200,000+.

4)
The All-Index® is an annual benchmarking survey used by organizations in various sectors. All-Index® is the registered
trademark of a product supplied by the All-In Diversity Project Limited. This information is given for the convenience of users of
this document and does not constitute an endorsement by BSI of the product named. Equivalent products may be used if they
can be shown to lead to the same results.

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Age ranges Policies

Age ranges cover: These questions consider the policies that an
• 18 – 25; organization has in place and how they are applied.
• 26 – 35;
Common people related policies include:
• 36 – 45;
• equal opportunities policy;
• 46 – 55;
• anti-discrimination policy;
• 47 – 65; and
• anti-bullying and harassment policy;
• 66 – 75.
• right to dignity at work;
• Above statutory/legal retirement age.
• mental health and wellbeing;
Recruitment methods • whistle-blowing policy;
The aim of this question is to understand whether some • grievance policy/procedure;
recruitment methods are more effective at increasing • diversity and Inclusion policy;
levels of diversity than others.
• flexible working;
How many appointments linked to diversity were • career break (sabbatical) arrangements;
made and through which recruitment methods? • adoption leave;*
Methods can include: • maternity leave;*
• internal promotion and development; • paternity leave;*
• careers fairs; • shared parental leave;*
• graduate programme; • company paid sick leave;
• employee referrals and recommendation scheme; • private healthcare;
• recruitment and search firms; • childcare, eldercare or other family care; and
• external advertisements and job postings (print/online); • support for childcare such as nursery vouchers or
• social media (i.e. LinkedIn, Facebook, etc.); a creche.
• speculative approach (employee approached you); and *as per the organization’s policy and practices
• others as used by the organization.
Do policies and benefits to everyone in the
Common employee contract types organization in the same way or does it vary based on
Contract types include the following: things such as role, location and so on?

• permanent employees; Training and support

• temporary, contracted, seasonal or fixed-term employees; What training does the organization provide in relation
• zero-hours’, “At will”, “no work guarantee” contracts; to diversity, equity and inclusion practices?
• freelance;
Examples of training can include:
• other.
• dealing with harassment, bullying and dignity at work;
Level of seniority • dealing with discrimination (gender/sex, racial,
Levels of seniority include the following: religious, physical capability, or other);
• entry level/new starter up to team leader or • how to report discrimination, bullying and
supervisor; harassment;
• team leader or supervisor; • organizational policy and legislation – diversity, equity
• manager (oversees Team Leader or Supervisor); and inclusion;

• head of department (oversees manager); • conscious and unconscious bias;

• director/VP/partner or “C”-level (oversees manager • language, stereotypes and intercultural competence;

and/or head of department); and • challenging inappropriate behaviour;
• CEO or MD. • leading managing and/or engaging with diverse groups;
• other (please specify); and

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• does the organization provide additional training, • explicit messages from a senior leader on diversity
development or support for specific groups, such as and inclusion when joining;
women, LBGTQ+ and/or non-binary, ethnic, minority • performance review:
or other under-represented groups?
• clear and consistently applied criteria for
Recordkeeping and analysis performance reviews;
Examples include: • third-party review of performance to check
for fairness;
• maintaining effective records can help organizations
monitor the effectiveness of their policies and practices; • exit interviews or exit surveys.
• keeping records on staff turn-over levels (attrition Support from organization leaders
or churn);
Has a representative from the board or the senior
• reasons for leaving (exit interviews/reports); management team done any of the following:
• equality of pay and bonuses; • communicated an organization-wide message on
• job applications by gender, ethnicity, sexuality, diversity, equity and inclusion;
disability or other; • communicated a strong message on gender equality;
• harassment, bullying or discrimination claims received; • had meetings with women’s, minority, LGBTQIA+ or
• outcome of harassment, bullying or discrimination other employee network or staff group;
claims; • reviewed and/or approved an diversity, equity and
• promotion by gender, ethnicity, sexuality, disability inclusion strategy;
or other; • reviewed and/or approved monitoring reports
• returners from maternity/parental leave; and and action;
• other (please specify). • spoken at an internal event(s) about diversity, equity
and inclusion;
Diversity, equity and inclusion
• spoken at an external event(s) about diversity, equity
Does the organization actively promote diversity, equity and inclusion; or
and inclusion, and if so, who is responsible for doing it?
• been seen as a visible role model for women,
LGBTQIA+, ethnic, disability or other group(s)?
Does the organization have any of the following practices
in place to support diversity, equity and inclusion? External stakeholders
• advertisement: Does the organization have a policy of actively
• inclusion of a statement around valuing diversity in engaging with suppliers/providers which are owned by
job packs; under-represented minorities and groups?
• reviews of job descriptions for visual or textual bias
Employee survey sample questions
(relating to age, gender, ethnic group etc.).
Organizations can select questions based on what they
• talent search:
wish to evaluate, learn or benchmark.
• advertising and recruitment using diverse websites,
recruitment fairs, events, etc; For an employee profile.
• explicitly request diverse candidates when using • How long have you worked here?
recruitment agencies or executive search firms;
• What attracted you to the organization?
• selection:
• What is your main reason for staying with the
• training on bias and reducing discrimination for organization?
those involved in recruitment;
• transparent and consistent criteria for evaluating Examples of answer options include:
candidates; • pay and benefits;
• diverse representation on interview panels; • location;
• induction: • the role and career opportunities;
• provision of information about diversity and • knew someone who already worked here/
inclusion policies on joining; recommendation;
• information on employee networks or other • needed a job;
support initiatives for diverse groups;

52 © The British Standards Institution 2023

 PAS 1948:2023

• wanted to work in the sector/industry; and • Employees can be asked which of the following are
• which best describes the team or function you the biggest factors when implementing an effective
work in? diversity, equity and inclusion strategy? Possible
answer choices might include:
• leadership/board commitment to supporting diversity,
Employee sentiments
equity and inclusion;
For these questions employees are asked to indicate
• having a mix of employees from many countries
how much they agree or disagree with the following
and backgrounds;
statements.
• policies and practices that support diversity, equity
• The organization understands and supports my needs.
and inclusion;
• The organization has created an open and trusting
• employee resource groups (ERGs) that provide
environment where people feel safe and encouraged
support to minority groups in the business;
to share their views/opinions.
• unconscious bias and anti-discrimination training
• The organization recognises and rewards individual
for employees;
and team performance. The organization inspires
people to be the best they can. • women or minorities on the Board;
• I feel valued by the organization. • HR practices that support diversity, equity and
inclusion such as screening CVs, exit interviews, etc;
• The organization has a culture where everyone
supports and respects everyone else. • employee surveys measuring diversity, equity
and inclusion;
• The organization encourages a culture where different
teams work together to achieve common goals. • role models and mentors;
• There is some internal conflict and competition • designated team/individuals responsible for managing
between teams in the organization. diversity, equity and inclusion;
• The organization communicates key messages
Employees can be asked which one of the following
consistently, clearly and openly.
best describes inclusion. Possible answer choices
• I think the organization offers the same benefits to might include:
all employees.
• feeling like you belong;
• My manager is supportive and trusts me to do my job.
• not being treated differently to everyone else;
• My manager recognises and rewards performance and
• feeling valued.
achievements.
• being accepted for who you are.
• My manager treats everyone in the team equally
and respectfully. • having the same opportunities as everyone else.
• My manager motivates me and encourages me • being seen as part of the team.
to succeed. • not being the only one who looks or behaves like you.
• I trust and respect my manager. • not feeling like you have to change to fit in or
• I trust and respect the people I work with. be accepted.
• I get most of my knowledge and information about • feeling like a part of the team.
the organization from my manager. • having the same views, opinions and outlook
• I get most of my knowledge and information about as others.
the organization from my colleagues and people • feeling comfortable enough to say what you really
outside my team. think/disagree with others.
• on a scale of 1 to 10 (with 1 being “not very” and
Response ranges can include: 10 being “very”) how inclusive would you say your
• strongly agree; organization is?
• agree; • which one of the following would you say best
• somewhat agree; describes diversity in an organization?
• neither agree nor disagree;
• somewhat disagree;
• disagree; and
• strongly disagree.

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PAS 1948:2023

Employees can be asked which one of the following

best describes diversity in an organization. Possible
answer choices might include:
• range of nationalities;
• range of ages and cultural backgrounds;
• range of skills and experiences;
• range of abilities;
• having different views, opinions or outlooks to others;
• being able to challenge the norm;
• being able to think differently to everyone else; and
• on a scale of 1 to 10 (with 1 being “not very” and
10 being “very”) how would you rate the level of
diversity in your organization?

54 © The British Standards Institution 2023

 PAS 1948:2023

Annex E (informative)
Glossary

Organizations are encouraged to develop a “Glossary

of Terms” to support their overall diversity, equity and
inclusion strategy.

This includes the terms, terminology, words, language

and expressions they consider to be acceptable or
unacceptable within the organization based upon their
operations.

Some common examples are provided below:

• “queer” – to describe an individual that identifies as
a member of the LGBTQIA+ community is acceptable
in some countries but seen as unacceptable in others;
• “queer as folk” – a term historically used to describe
the fact that human beings can often behave or act in
a way that is odd, strange, unpredictable or illogical
may continue to be used and accepted in some places
but not in others;
• “Chinese whispers” – a parlour game known in some
parts of the world as Telephone, where a message is
whispered from one individual to another in a chain
with the last announcing the message as received by
them. Inevitably the passing of the message will result
in inaccuracies along the way so that the message
announced by the last individual is almost always
slightly different from the original message. The term
is often used in the workplace to suggest rumours
and gossip. The term, however, has its historic origins
in the colonial past and as a result, many now find
this phrase unacceptable;
• “Ladies and gentlemen” – a long established
salutation to acknowledge members of an audience,
and is now viewed by many as being outdated due
to it conveying a rigid expectation of gender and
excluding those who identify as non-binary, gender
fluid or multi or trans gender.
NOTE This salutation is often replaced with more
inclusive salutations such as “honoured guests” or in
the case of written communications “Dear everyone”
or “Dear all”.

© The British Standards Institution 2023 55

PAS 1948:2023

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56 © The British Standards Institution 2023

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