Leading inclusion

Leading InclusionA Guide to Leadership of Equality, Diversity and Inclusion in the Learning and Skills Sector

A Guide to Leadership of Equality, Diversity and Inclusion in the Learning and Skills Sector 3

Contents

1. Preface 04

2. Executive Summary and Introduction 05

3. Leadership of Equality, Diversity and Inclusion 09

4. Organisational Culture 15

5. The Business Case for Equality and Diversity 19

6. The East Midlands Regional Survey of Providers Leading Equality, Diversity and Inclusion 25

7. Approaches to Promoting Equality, Diversity and Inclusion 31

8. Inspection and Performance Management 36

9. Funding 46

10. The Learning and Skills Workforce 51

11. Sources of Support 54

12. List of Annexes. These are published separately. 56

13. Acknowledgments and Contacts 57

This Guide has been produced as an outcome of an East Midlands regional project sponsored initially by the Learning and Skills Council, now by the Young People’s Learning Agency (YPLA), the Learning and Skills Improvement Service LSIS) and by EMFEC, the East Midlands regional organisation for learning and skills.

June 2010


2. Executive Summary and Introduction

Executive Summary

2.1 This Guide is one outcome of an East Midlands regional project on inclusion, operated jointly by the YPLA, LSIS and EMFEC. At a time of major change and uncertainty in policy and funding for learning and skills, the Guide considers the key issues for sector leaders in establishing their colleges and training organisations as exemplars of good EDI practice. It considers what leadership of EDI means, in the contexts of wider leadership effectiveness and of organisational culture. The business case for EDI is assessed, both in terms of broad business effectiveness and with regard to sector benefits. The Guide reports on the findings of a recent survey of sector leaders in the East Midlands-and further afield- on good EDI practice, as well as those areas where improvement is still needed. Approaches to promoting EDI through people skills are also addressed.

2.2 This Guide looks at how public funding operates to resource provision for priority learners, many of whom have EDI characteristics. Workforce leadership is considered and sources of support for leaders in the sector are referenced.

2.3 The co-sponsors will continue to work together to assist the sector in supporting priority learners.

Introduction

2.4 This is a highly significant time for all those working to raise skills and promote social inclusion through education and training. The election of a new government follows the passage into law of the recent Equality Act 2010. The machinery of government has been re-tooled through the 2009 Act1, which created the Young People’s Learning Agency (YPLA) and Skills Funding Agency. The YPLA has responsibility for funding 16-19 learners or to 25 for those with a learning difficulty assessment. The Skills Funding Agency manages post-19 learning, including the National Apprenticeship Service. The 2009 Act gives local authorities important new responsibilities for planning and commissioning services to the 16-19(25) age group. Their role builds on their accountabilities for the education and welfare of all young people under the Every Child Matters programme.

2.5 All three of these planning and funding bodies have an equality duty in their service delivery. The YPLA describes its mission as being “to champion young people’s learning”. Its National Commissioning Framework2 (NCF) for 2011-12 is a means to that end. The NCF highlights the needs of vulnerable learners. Local authorities are charged with meeting those needs under the 2009 Act and have been guided by the Local Government Association through its “React” programme, including advice on vulnerable learners

1 Apprenticeships, Skills, Children and Learning Act 20092 National Commissioning Framework for the provision of learning for young people in

England aged 16-19, or to 25 if subject to learning difficulty assessment. YPLA April 2010.

1. Preface

This Guide is the outcome of a joint project on Leading Inclusion by LSIS, YPLA and EMFEC, to support leaders of college and training organisations at a time of significant structural change. The focus for the year ahead will be on high quality provision for priority learners, both young people and adults. Many of these learners are vulnerable and are at the heart of the agenda for equality, diversity and inclusion.

Progressive leaders have quickly recognised the importance of meeting all learners’ needs. As sector leaders, you are going beyond mere compliance by;• evidencing improvement as part of the

raised expectations for equality and diversity• seeking to re-focus your resources without

compromising quality• taking advantage of the lead time between

the announcement (2008) and arrival of the Equalities Act 2010

• aiming to deliver excellent services to all learners.

To support sector leaders further, the partners (LSIS, YPLA and EMFEC) are pleased to present this Guide to Leading Inclusion which aims to;• strengthen leadership understanding,

knowledge and expertise in equality, diversity and inclusion, for providers working with learners of all ages and backgrounds

• support more effective leadership by governors and supervisory boards as well as by leaders operating at all levels of management and delivery.

Although the Leading Inclusion project has been based in the East Midlands, it reflects national requirements in promoting equality, diversity and inclusion. It will assist leaders of all types of college and training organisation across the country in meeting their goals for inclusion. Phase one of the project has involved the production of this Guide and a sector survey of the issues affecting success in this field. Results are summarised in this guide and form a major annex.

The partners will continue their commitment to this project. Phase two is already under development and is intended to support implementation of the Equality Act 2010 requirements.

We invite sector leaders to consider the approaches utilised here and to provide feedback and instances of best practice to the contacts detailed in the Guide. By taking this opportunity to continue your own professional development, as Leaders of Inclusion who wish to go beyond compliance, you will help reduce disadvantage, narrow the gaps in attainment and demonstrate the value that all learners bring to society.


Use of Terms

2.11 The terms “equality and diversity” are often used interchangeably, although useful distinctions can be made. This Guide has adopted the approach used by the LSC and LSIS publication, Equality and Diversity in Self-Assessment: Guidance for Colleges and Providers (October 2009. See LSIS website). This cited the Equality and Human Rights Commission definition of equality:

• equality of outcomes • equality of process (fair treatment,

or being treated with dignity and respect)

• equality of autonomy (empowerment, or the degree of choice and control).

The FE system is an important driver of all these aspects.

2.12 The LSC and LSIS utilised a definition of diversity by the Chartered Institute of Personnel and Development in the self-assessment guidance:

‘Diversity consists of visible and non visible factors, which include personal characteristics such as background, culture, personality and work style in addition to characteristics that are protected under discrimination legislation in terms of race, disability, gender, religion and belief, sexual orientation and age. Harnessing these differences will create a productive environment in which everyone feels valued, their talents are fully utilised and organisational goals are met.’

2.13 With regard to inclusion, two broad approaches may be useful here. One is to recognise the importance of socio-economic inclusion. This was given enhanced significance by the Equality Act 2010, with a new public sector duty to consider reducing socio-economic inequalities. The second approach is the context of learning. Inclusive learning has been defined as:

“An educational model, as opposed to a political one … [where] inclusive learning does not equate with locating the learner within the mainstream or consider the social dimensions of education which extend wider than the learning activity. Instead … inclusive learning operates … at the level of the education system, the institution and the individual teachers and learner”3.

2.14 Both these approaches are of value in a guide for sector leaders. The socio-economic duty in the 2010 Act will translate into funding and performance requirements on providers, summed up by Ofsted as “narrowing the gap” in achievement between groups (see Section 8). The inclusive learning approach, however, is value-driven and qualitative. It is about the kind of education or training organisation you run, as well as how the planners and funders support learners into learning. This is taken further in the next section on leadership.

3 By Anderson et al, cited in: Beyond prejudice: inclusive learning in practice. Smith V and Armstrong A, LSC/NIACE/LSDA 2005.

(see www.lga.gov.uk, where a useful high- level summary of the 2010 post-16 policy changes may also be found). The Skills Funding Agency, funding adult learning and skills, describes itself as “demand-led and customer-focused”. For learners, it will offer an advancement service/personal skills account, through which they can find out about the range of courses, funding, and information and support available.

2.6 Among a range of provisions made by the Equality Act (summarised in Annex 1) is the new public sector duty on Government Ministers, departments and key public bodies such as local authorities and the NHS to consider what action they can take to reduce the socio-economic inequalities people face. The duty will affect how public bodies make strategic decisions about spending and service delivery. It will enshrine in the law the role of key public bodies in narrowing gaps in outcomes resulting from socio-economic disadvantage.

2.7 These changes have occurred in a context where equality and inclusion have already been re-positioned by Ofsted in its Common Inspection Framework for further education and skills, 2009, where, among other questions, the following are asked: How effectively does the provider actively promote equality and diversity, tackle discrimination and narrow the achievement gap? These issues are explored in Section 8.

2.8 Taken together, these legal and regulatory changes mean that schools, colleges and training organisations receiving public funding will need to look afresh at how they work to narrow the gap in the achievements of learners, promoting equality and diversity.

2.9 In the past, many providers worked hard and well to promote equality and inclusion. In some providers though, members of the leadership team (including the governors or supervisory board) might have thought that an open door, anti-discriminatory policy was enough to meet the equality requirements; that promoting equality and diversity was someone else’s job. Now, the moral imperative comes together with planning, funding and inspection decisions to require the leadership team of every publicly-funded provider to focus on equality actions and outcomes.

2.10 This publication is a response to the new context. It is intended to provide leaders at all levels within a post-16 education and training provider with a guide to more informed and more effective leadership of equality, diversity and inclusion. Although originating in the East Midlands, the guidance has been written to be of benefit to all colleges and training organisations.


3.1 This Guide aims directly at leaders of colleges and training organisations. It provides advice on leadership issues with some trepidation; while there is expertise in leading EDI in the sector, there are few who would claim to be experts. This is an area where pride may come before a fall, be it through a learner complaint, through self-assessment or the next Ofsted report.

3.2 With its EDI focus, this Guide does not offer a treatise on leadership-there are plenty of those. What it does consider here are some important issues for leadership that have resonance for Boards and senior teams aiming at excellence in EDI. It is evident that many best-practice approaches to leadership in general will benefit EDI, as they are values-driven, just as best inclusion practice is.

3.3 In searching for approaches to improving leadership that bring out issues most relevant to EDI, one text has been selected among many as a reference point. This is because it asked and attempted to answer the provocative question below.

Why Should Anyone Be Led by You?

3.4 Why Should Anyone Be Led by You?4 Is the title of a readable book that combines a review of literature on leadership with findings which help answer the question. Looking at examples of leadership around the world, including a British secondary school, the authors reach conclusions which are as relevant for leaders focusing on EDI as those dealing with cash-flow.

This is because leadership is seen through its success in achieving business goals and in creating the key requirement of having followers; those who make any organisation succeed or fail through their work.

3.5 This Guide will simply draw on the most valuable lessons the book’s authors, Goffee and Jones, offer in terms of our EDI focus. One of these is that leadership skills can be drawn upon at all levels of an organisation. However, many organisations are structured in ways that, in the authors’ view, “kill” leadership. They found this occurred in all types of organisation: private, public and not-for-profit. Conformists or role players uncertain of who they are or what they stand for were all too evident, frustrating themselves, other leaders and, of course, the would-be followers. Yet they had leadership roles. Thinking this through in EDI terms for the purposes of this Guide, sometimes the need in education and training to comply with legal or regulatory requirements- important though that is- may be felt to obstruct true leadership based on values and commitment. It should be possible to do both, perhaps ideally meeting EDI regulatory requirements as a product of best-practice ways of working, through leadership of EDI values at all levels in your organisation.

3. Leadership of Equality, Diversity and Inclusion

4 Why Should Anyone Be Led by You? Rob Goffee and Gareth Jones, Harvard Business School 2006.

Priorities

2.15 Government policies for public funding have remained focused for some years on those areas of most need, recognised in Public Service Agreement (PSA) targets, 2008-11. These include powerful EDI ambitions, such as “Fairness and Opportunity for All”; a category that includes education targets. Details of these targets are available on departmental websites (Department for Education, www.education.gov.uk; Department of Business, Innovation and Skills, www.bis.gov.uk). In practice these translate into departmental priorities, although these are expected to change. For the Department for Education a key priority has been the concept of a 14-19 entitlement for all young people: to the right learning opportunities, and the right support. Some of the Department for Education priorities most relevant to the EDI agenda (under the former government) are summarised in its strategy for narrowing the gap in outcomes and attainments for young people. A two year research and development project, 2008-10, run jointly with the Local Government Association (see Department for Education and LGA websites), on “narrowing the gap” highlighted the types of children and young people who were in focus. These included those from poorer socio-economic groups (including white working class boys), those from certain ethnic backgrounds, those in care, those with special educational needs, poor school attenders and those excluded from school, young offenders, young carers, refugees and asylum seekers and those living with vulnerable adults.

This list was not exclusive and categories were seen as sometimes overlapping.

2.16 Funding for adult learning is also increasingly focused on those most at need. The new Skills Funding Agency (www.skillsfundingagency.bis.gov.uk) sees itself as an organisation working to route funding to colleges and other providers, primarily in response to learner and employer choices, within a policy framework. This includes the routing of funds for apprenticeships and Train to Gain. It also supports the Adult Advancement and Careers Service, Skills Accounts, integrated employment and skills services for the unemployed, offender learning, and informal adult learning. Once again this funding operates to serve PSA targets, in this case those managed by the Department of Business, Innovation and Skills. These focus on under-qualified adults and the skills needs of the economy. Although priorities may be expected to change with the new government these needs seem long-term.

2.17 Note: throughout the guide and for ease of reading the term equality, diversity and inclusion is usually abbreviated to EDI. Each section of main text is accompanied by “action points and considerations” arising from it, for use by the reader.


• Excitement: the feeling that leads to greater effort and performance, which is more than carrying on today the way we did yesterday.

• Community: followers want to feel part of a community with a shared sense of purpose and sense of belonging.

3.11 Many organisations in the learning and skills sector offer good or outstanding leadership, as Ofsted has noted. The values implicit in the best-practice leaders described by Goffee and Jones are values that most in education and training will see as important. That is not the same as saying they are always lived by or exemplified, as the context, challenges and operation of each provider will vary. However, if leaders in your organisation are seen as authentic; if you/they recognise good practice and show that it matters; if achieving goals is seen as exciting and fulfilling; and if your organisation is a community with a common purpose, then “situation sensing” would suggest good leadership is evident.

3.12 The factors described as exemplifying good leadership, above, are often also seen as characteristic of leaders who seek to promote excellence in EDI. The need to build best practice in EDI will be sensed -and evidenced- and communicated. Success in achieving EDI goals will be made significant and recognised. The organisation will have a strong base of inclusion values, will feel like a community and will be an exciting place to work, learn and achieve.

3.13 It is beyond the scope of this Guide to detail the approach taken by Goffee and Jones much further. Only some of their findings are presented here. As a leader you may wish to read more, either of their work or the many other sources on leadership, some of which are cited in their book. For now, the key elements described here can be seen as illuminating issues for leadership of EDI in colleges and training organisations. This is as important for governors and supervisory bodies as it is for other leaders.

3.14 Looking at another approach more directly related to colleges and training organisations, the leadership considerations for inclusive learning were addressed in Beyond Prejudice, referenced in paragraph 2.13. This work considered how good practice in inclusive learning could be developed at strategic and organisational levels. Six principles of good practice were identified for effective working with disadvantaged young people, describing a range of interventions and characteristics of provision. One of these was leadership and management, with five key elements:

• management recognition and support for inclusive learning

• quality assurance, including standards and indicators

• budgetary control • reporting to partners • long term planning.

3.6 In seeking to understand what enables effective leadership, Goffee and Jones make three points. Firstly, leadership is situational, influenced by its context. Secondly, effective leadership is also non-hierarchical; even in hierarchies, such as an army, doing things well means mobilising all the talents in well-led teams. Being given a title may confer authority but does not in itself make the title-holder a leader. Thirdly, leadership is relational: leaders need followers. Effective leadership is dependent on the relationship between the leader and the led. This relationship needs constant refreshment and its purpose needs re-stating.

3.7 On the matter of situational leadership, the authors cite examples of effective leaders having the skill of “situation sensing”; being able to sense what is happening with regard to issues in their organisations. This can be learned though experience, drawing on personal attributes alongside knowledge of how the organisation operates. It can lead to the feeling that, regarding an attempt at improvement, “It’s creating a real buzz”, or conversely “I just know it isn’t working well…” Responses can be “flexed” accordingly, in a timely way.

3.8 With regard to non-hierarchical leadership, the authors point to examples of leadership encouraged at every level of an effective organisation. The best organisations build capability throughout. As organisational success becomes more challenging in most lines of endeavour, supporting and growing leadership and initiative becomes essential.

3.9 In considering relational leadership, the authors emphasise the obvious point about leaders needing followers. The relationship might not always be harmonious but effective leaders know how to motivate followers.

3.10 The evidence of what followers want in a leader brings the authors to focus on the attributes which, taken together, can create the wish to follow.

• Authenticity, with leaders showing “the person they are” (what’s different about you that might make us want to follow you?). Authentic leaders display consistency between words and deeds, so are seen as genuine, with a “real self” that comes through. They communicate their values well. They create followers.

• Significance: followers need recognition for their contribution-they need to feel significant. All too often this doesn’t happen, sometimes because leaders feel they are too busy to give praise when it is due.


Leadership and the Learner

3.16 It is not intended that this guide details the many ways in which the learner experience may be enhanced by good EDI practice. There is an abundance of valuable evidence already, presented for example by LSIS (http://www.excellencegateway.org.uk). Case studies and staff development links for young people’s learning may also be found on the website of the Department for Education (www.education.gov.uk), following the links for 14-19. The National Institute of Adult Continuing Education, NIACE, produces guidance of high quality on adult learning. Evidence of the views of learners themselves may be found through published outcomes of the National Learner Panel and Framework for Excellence learner responsiveness indicator, for example. In seeking improvements, providers will always find the views of their own learners of greatest interest. The focus here is on leadership and how it may improve the learner experience.

3.17 Governors of colleges are responsible for the mission and educational character of their organisations. They must also ensure that a quality strategy is in place. The leadership function here -which should apply also to Boards of training organisations-is to ensure the right curriculum is in place to meet the needs of the learners targeted. This should then be made accessible and sustained to good or outstanding standards.

The right match of human and material resources support this; staff, facilities and equipment.

3.18 The development and improvement of qualifications for young people up to age 19 in England, is currently the responsibility of the Qualifications and Curriculum Development Agency (www.qcda.gov.uk). For adult vocational learning and for skills in the economy the UK Commission for Employment and Skills (www.ukces.org.uk) now has a key role. It is also responsible for the work of Sector Skills Councils. Both these organisations have strong EDI requirements and provide examples of how these are evidenced through their websites. The UKCES in particular has researched how skills and qualifications in the labour market may be related to the needs of individuals to improve their own qualifications for better work.

3.19 Ofsted requirements create a sound context5 for reflecting on leadership with regard to the learners’ experience (more detail is provided in Section 8). In the terms used by Ofsted and utilised by most providers in their self-assessments, this is focused on quality of provision and outcomes for learners. These factors also inform judgements of the quality of leadership and management.

5 Examples cited are from the Ofsted Handbook for the inspection of further education and skills from September 2009.

3.15 There is recognition here that the value-driven ambition must be underpinned and served by the pragmatics of funding, data, performance evidence, relationship management and planning. The need for providers to establish protocols of good practice is emphasised. A fuller account of the principles is provided in Annex 2, along with an inclusive learning checklist from the same source, to help develop practice.

Action points and considerations • Whyshouldanyonebeledbyyou?

Which of your values and behaviours inspire the people you lead? Which may not?

• Inthecontextofcreatingbestpracticein EDI, the same question applies: why should anyone be led by you? What do you do yourself to achieve positive EDI outcomes, directly or through your teams?

• Whatisthecontext for leading the improvement of EDI goals and indicators in your organisation? How good are you at “situation sensing” when it comes to EDI: with your Board…your executive leadership team…other leaders…and followers? What is your sense of the situation facing learners and would-be learners of different types in your organisation…or those who could be learners?

• Isyoursahierarchicalorganisation?If it is, then does the hierarchy help or hinder the achievement of EDI goals and objectives? How straightforward is it to create a well-led team or teams in tackling EDI goals…do roles and job-titles help or hinder this?

• Areworkingrelationshipsstructured so as to maximise the opportunity to improve EDI outcomes? Is your EDI leadership clear to your followers… do they actually follow you and are the intended outcomes achieved?

• Areleadersinyourorganisation-includingthe Board and including you- authentic in leading EDI? How do you know? Do the staff and learners say so?

• Doleadersinyourorganisation-includingthe Board and including you- give high significance to EDI goals, objectives and outcomes? Do they/you recognise, highlight and celebrate the achievements?

• IsthereasenseofexcitementaboutEDIin your organisation, or does the need to comply with regulatory requirements tend to dominate people’s feelings and responses?

• Isyourorganisationacommunitywithashared purpose in education and training? Is that exemplified by your leadership of EDI goals and in their outcomes?


4.1 This Section will explore the ways in which leaders in colleges and training organisations can facilitate positive change to their organisation’s culture by enhancing or including both the principles and practice of equality, diversity and inclusion (EDI). By referring to the research in Section 6 and other sources, this Section presents some of the opportunities and challenges that arise when attempting to align EDI as a positive component of an organisation’s culture, and outlines some strategic and practical ways forward for leadership in the learning and skills sector. College leaders are advised to also read the recent LSIS publication on equality, diversity and governance, which other providers may also find of value in its approach to organisational culture6.

4.2 EDI is primarily concerned with fairness of opportunity within an inclusive environment, which for the provider relates to learning, teaching and employment. An organisation’s culture is made up of diverse components, some of which are intangible (values, ethos and attitudes) and others that reflect the general ‘health’ of an organisation (the level of staff and learner engagement, reduced staff turnover, greater productivity and success rates, for example). There can be benefits to aligning the two elements, showing the organisation to be an employer and learning provider of choice. As these benefits are closely aligned to the provider’s desire to pursue excellence in learning, teaching and employment it therefore makes sense to ensure that EDI action produces meaningful results.

4.3 However, whilst most efforts to link EDI to organisational culture can often be seen in public communications and policy documents that reflect organisations’ high-level plans, this essential link tends to be less prominently featured when it comes to subsequent activity. In particular, links may be weak between EDI goals and clear, measurable outcomes that address inequality and exclusion. This reflects in lost opportunities for providers (for example the opportunity to make quality assurance processes easier to manage) but also increases the risk of legal non-compliance with equalities legislation.

4.4 It may be that this challenge is in itself reflective of other difficulties. For example, tangible measures (such as policy changes) are comparatively easier to deal with, but the more informal elements that make up an organisation’s culture may be more difficult to address. These are nonetheless central to a provider’s functions and activities and require more in the way of long-term activity, such as reflective training interventions (see Section 7). Whilst benefits such as those outlined in the business case in Section 5 can be achieved through these long-term efforts, they will often have to be sustained and pushed forward in the face of opposition, such as a lack of understanding as to the relevance of EDI to a provider’s work. This is where confident, informed leadership can make a crucial difference.

4. Organisational Culture

6 Equality, diversity and governance: Brief Guide for governors and clerks in further education colleges. LSIS 2009

3.20 Two relevant examples affecting judgements of quality of provision may be cited in this context. One is the evaluative statement: interesting and appropriate teaching and learning methods and resources inspire and challenge all learners and enable them to extend their knowledge, skills and understanding. The second is the evaluative statement: learning, teaching, training and assessment promote equality and support diversity.

3.21 These evaluative statements and areas of judgement are cited because success in these areas-and others utilised by Ofsted with regard to outcomes and quality- will help determine the judgement for leadership and management. With regard to leadership of equality and diversity, related to the learner experience, the following is one of the factors inspectors will take into account: arrangements (are in place) to ensure all learners can participate, including those with learning difficulties and/or disabilities, and that they have opportunities to give their views on provision.

3.22 Also with regard to leadership and management, the following is an illustrative grade characteristic for a judgement of outstanding: the development or progress of all or nearly all its users (including those from vulnerable groups) in relation to their starting points is improving significantly and the achievement gaps have narrowed significantly.

3.23 These examples are cited to encourage a focus on the role of leaders in improving the experience and outcomes for learners.

Action points and considerations • HowdoestheBoardandmanagement

team in your organisation demonstrate leadership in ensuring the quality of the learning experience and outcomes for all learners?

• Howdoleadersinyourorganisationtakeaccount of and act on learners’ views on their experience of provision, throughout the learner journey?

There are more action points related to inspection and performance management in Section 8.


4.8 Equality evidence for action. A common and unfortunate feature of equalities work is that plans and research do not necessarily lead to action. This was experienced by some of those engaged in the research that supports this guide (see Section 6). The new Equality Act requires monitoring across particular themes, such as the gender pay gap and the setting of equality objectives based on these and other data and information. Evidence and information on equality can be used as the impetus for positive change, related to the organisation’s key priorities. It is therefore important to establish an evidence base for equality by incorporating effective monitoring data with equalities impact assessment (EIA) processes.

4.9 Organisational standards on EDI. The two preceding activities can help your organisation identify how its vision and objectives, culture and preferred operating styles can incorporate and advance equality and diversity. If conducted effectively, they can also help you to define a strong organisational standard on EDI. This standard should represent a commitment to advancing EDI and an effective plan to do it. It should identify the types of behaviours that are encouraged and those which will not be tolerated and tackled actively (e.g. discriminatory behaviour, bullying and harassment etc). The standard should feature in job roles throughout your organisation, and particularly for staff with learner-facing responsibilities.

4.10 Effective engagement and communications. Effective engagement can play a key part in demonstrating visible commitment to the principles and practice of EDI. Research by the Equality Authority of Ireland on disability has found that a more inclusive culture can be achieved where leaders show a genuine concern, for example in developing their strengths, and having positive expectations of what they can achieve, understanding the issues faced by people of different backgrounds, including people in decision-making through staff and learner networks. This point relates clearly to the best characteristics of leadership described in Section 3.

4.11 Similarly, good internal and external communications (on both a strategic and operational level) also show how the provider is committed to EDI in all aspects of its services and business functions. This is part of ensuring that learners, staff, visitors and stakeholders understand that EDI is everyone’s right and responsibility, also clarifying what potentially contentious issues such as positive action mean in practice. The opportunity should also be taken to celebrate good work, establishing the provider’s place as part of the community served.

“Our aim has been to create a culture where the firm’s values of respect and cooperation would be practiced by every individual in their everyday work…our wider HR strategy could be summed up as “attract, retain, enable” and our work on diversity supports that” Adrian Barlow, Partner and Head of Property Group in the solicitors’ partnership Pinsent Masons (cited in Talent not Tokenism: the business benefits of workforce diversity. EHRC, CBI and TUC 2007)

An adult and community learning provider has found that developing an inclusive environment at the point of contact with learners has encouraged more potential learners to join their organisation. http://www.excellencegateway.org.uk/page.aspx?o=inclusivepolicies

4.5 There are useful starting points for leaders seeking to identify and adapt their organisational culture. These may be summarised under the following headings.

A. Context and confidence B. Equality evidence for action C. Organisational standards on EDI D. Effective engagement and

communications

4.6. Context and confidence is about understanding how key drivers (the legal framework, local and regional demographics, best business practice and levels of representation) are relevant to your work as a provider. This will help in developing “equality confidence” and making EDI work for you, for example in dealing with current issues and anticipating future changes and their impact on the provider, such as the learner profile.

4.7 As a college or training organisation you can gain equality confidence by establishing how EDI is linked to your business operations and the inclusive nature of your employment and learning environment. As part of your considerations you should think about “live” EDI issues as they relate to the law, learners and the workforce; how you have linked this understanding to organisational processes; and the way in which your organisation shows its commitment to the EDI agenda at a strategic level. This may happen, for example, through regular agenda items on EDI at leadership team or Board meetings leading to improvements; also the actions of high-level, responsible and accountable EDI champions; and through effective capacity-building across areas such as self-assessment and quality improvement. Considering these points will help you identify where the organisation is at with regards to equality confidence, what can be celebrated and what remains to be improved.


5. The Business Case for Equality and Diversity

5.1 For the employers served by colleges and training organisations- and for themselves, as bodies with corporate goals and financial responsibilities- it is essential to understand the business case for equality and diversity in practice. This Section considers this business case in two forms. The first form takes account of the world outside; the wider business case, in the national global economy and as seen by the commercial sector. The second is the business case for a provider in actively promoting equality, diversity and inclusion in education and training. It is understood that the learning and skills sector sees EDI as part of its core business to a significant degree. However, barriers remain in place for some of the most vulnerable learners and there is still an achievement gap to be narrowed.

The Wider Business Case

5.2 Societies around the world are changing rapidly, so the private, public and voluntary sector services meeting people’s needs are changing with them. In developed societies like the UK shifting demographics, as reported by the National Office for Statistics (www.statistics.gov.uk), are affecting labour markets, social systems and the needs of individuals. Even in the recent UK recession there were skills shortages in the labour market and skills gaps in the workforce, which is ageing. The changing labour market has more women and people from ethnic minorities.

There are increasing global economic impacts on UK businesses; and increasing economic, social and environmental demands for changes in work patterns. These changes were noted in the Leitch Review of Skills, 2006, and detailed in the more recent Skills Strategy (Skills for Growth, BIS, 2009).

5.3 These changes are of international concern, as the Organisation for Economic Cooperation and Development (OECD) has reported. Globalisation and the rise of the knowledge economy are driving an increasingly competitive business environment, where it has never been more important for businesses to reflect the diversity of their markets. As an instance of this, the OECD has published research on how gender equality can spur economic growth. This suggests that trends in gender equality should be incorporated more firmly into economic models for long-term growth. The authors state that:

“Such models would probably show two things. First, that the gap in performance between OECD economies has a compelling gender-related dimension. And second, that without a change in attitudes, the growth prospects of many OECD countries will remain severely compromised”7.

7 Roger Mörtvik and Roland Spånt, OECD Observer No 250, July 2005

Summary

4.12 These approaches provide a strong foundation for continuously improving a culture of equality, diversity and inclusion, allowing providers to enhance their work in relation to learning, teaching and employment. Whilst there may be obstacles to their improvement, these can be identified and minimised progressively. Dividends in equality and inclusion can be achieved through good practice, which will benefit learners and enhance staff commitment.

More detail on the issues raised here is provided in Annex 3.

Action points and considerations • Howwouldyoudescribeyourorganisational

culture from the EDI perspective? • Whatpositiveactionshaveyoutakento

improve the culture in order to promote EDI? • Howdoyouknowhoweffectiveyouhave

been in this, ie how do you assess cultural improvement for EDI purposes?


Successful business outcomes will require hard measures for assessment of impact, and systems to collect and act on data. Equality and diversity should be part of all organisational change processes and integrated into the fabric of the organisation.

Figure 1: The Equality-Diversity Chain

Organisational Context

Business Strategy

Equality & Diversity Strategy

Equality & Diversity Policies & Practices

Employee OutcomesCommitment;

Motivation;

Job satisfaction;

Life satisfaction;

Work-life balance;

Reduced stress

Employee PerformanceReductions in absenteeism & labour turnover;

Improved employee relations;

Innovation & creativity

Organisation PerformanceAccess to new labour pools and markets;

Attraction of high calibre applicants;

Enhanced service levels & customer satisfaction;

Enhanced corporate reputation

Work groups Line Managers Trade unions

5.4 For the UK the Equality Act 2010, shaped by European-wide equality directives, aims to provide an ‘impetus’ to businesses to respond to these changes. It is summarised in Annex 1. Amongst other measures, it will introduce changes to positive action provision. For individuals, the Act will set standards for fair competition, ensuring people are not held back by discrimination or from realising their potential. For employers, it seeks to ensure they recruit the best people for the job, not hedged-in by stereotypes about who can do which job, with a productive workforce free of discrimination and prejudice.

Non-compliant businesses which fail to value diversity and promote equality risk closing the doors on public sector funding opportunities; reputational damage; and legal challenge, with the associated high costs.

5.5 There are many research studies on the wider business benefits of EDI. For leaders in the learning and skills sector the two cited below may be of value in developing thinking and strategy. One is a review of the international evidence of business impact, which was published in Ireland in 2007, authored by Kathy Monks8. This found that investment by companies and organisations in initiatives that promote equality and foster diversity generates substantial benefits for both employees and employers. The second is the joint UK report from the EHRC, the CBI employers’ organisation and the Trades Union Congress, Talent not Tokenism, (see paragraph 4.4).

This identified organisations which have benefited from investing in EDI in their workforce development to overcome business challenges. As a result, they have improved their organisational performance.

Figure 1 shows the equality- diversity value chain utilised in the Kathy Monks report to map the linkages between investment in equality and diversity initiatives and the outcomes for employees and employers. Annex 4 provides an illustration of how the value chain could be populated to show the strategies and outcomes for a college or training organisation.

5.6 The Monks report provides evidence for the equality and diversity benefits of the elements in the value chain. It goes on to identify those factors critical to the success of companies engaged in equality and diversity initiatives. These include top management support, with leaders demonstrating the importance of equality and diversity; the incorporation of equality and diversity into an organisation’s vision and values, ensuring that it becomes a core activity; the integration of equality and diversity into business objectives with reward and recognition of achievement; the assessment of the specific needs of the organisation and the tailoring of the management of diversity to those needs; the spread of ownership for equality and diversity throughout the organisation; and involvement of employees in the development of equality and diversity policies and practices, with training as required.

8 Kathy Monks, The Business Impact of Equality and Diversity: The International Evidence. The Equality Authority and National Centre for Partnership & Performance. Dublin 2007.

Diagram produced with kind permission of NCPP.


5.11 In summary, colleges and training organisations which build their EDI expertise will benefit from performance improvements, attract recruit and retain staff from the widest talent pool, enhance their reputation and reduce risk of litigation from failing to comply with the law or meeting contractual obligations. They should also open new markets for income-generating business, in helping other organisations raise their performance in EDI. Some readable recent evidence of how providers have gained these benefits and improved the experience of learners may be found in Ofsted’s publication Talisman. Issue 79 from September 2009 features equality and diversity. Issue 84 from March/April 2010 records how some providers have made progress in work with those not in employment, education or training; Workstep, where providers are helping disabled people find employment; and offender learning programmes. It also highlights Ofted’s review of factors linked to success in reducing the numbers of those not in education, employment or training (NEETS)11.

Action points and considerations • Ifyouoffertrainingservicestoemployers,do

these include developing EDI knowledge and skills, with good-practice applications?

• Doyourownworkplacepracticessupportthe attraction, recruitment, retention and development of a diverse workforce?

• DoesyourprofileofstaffandBoardmembers show similar characteristics to that of the communities you serve? What is the profile of your organisation in terms of equality and diversity benchmarks?

• Doyouprovidecareerdevelopmentopportunities designed to increase diversity in higher-level positions within the organisation (e.g., mentoring, coaching)

• Ifyouareaproviderservingtheneeds of employers, do you offer them training on the business benefits of EDI?

• Whatchangeshavebeenintroduced to your business strategies to support EDI initiatives?

• Doyourprocurementpracticesensureequality and diversity in business with your organisation’s suppliers, contractors etc?

• Whencarryingoutself-assessmentprocessesdo you use curriculum reviews to identify how more diverse learner groups could be served, with a focus on government-designated priority learners?

11 The effectiveness of local authority area strategies in reducing the numbers of young people not in education, employment or training: what works and why. Ofsted, March 2010.

The Sector Business Case

5.7 For the UK and East Midlands, lifting national/ regional business performance, stimulating enterprise and widening social and economic opportunity all require higher-level skills. In a context where the national Skills Strategy (see 5.2) will increasingly influence the resources colleges and training organisations can attract, providers are advised to address the regional economic strategy (RES) applicable to their business planning. For example, the Regional Economic Strategy for the East Midlands9

places EDI as one of three underlying themes that will help achieve the ambitions for the regional economy. This RES addresses, among other elements: employment, learning and skills; innovation; cohesive communities; and economic renewal. It is currently being updated to reflect the requirements of 2010.

5.8 The FE and skills sector has played a crucial part in responding to economic challenges already, as the national Skills Strategy noted. Its responsiveness to very diverse and often vulnerable, formerly excluded or under-achieving learners requires a wide range of skills from a learning and skills workforce that is itself diverse. Workforce diversity will help attract under-represented learners to FE; in addition to those choosing to stay on already in the 16-18 age group, the priority learner in the sector for public funding is the EDI learner.

5.9 As the YPLA’s National Commissioning Framework (see paragraph 2.2 and Section 9) gets underway, local authorities (LAs) procuring future provision will be looking for those providers who can be identified as outstanding in responding to and meeting the needs of priority learners. The approach of LAs to commissioning will take account of new measures being introduced as part of the Equality Act 2010; they are now legally required to evidence how they are using procurement activity to promote the EDI agenda. Other measures being introduced in the Equality Act will place requirements on all providers to promote equality and eliminate discrimination through their role as an employer or provider of services.

5.10 Providers demonstrating good or outstanding practice in equality aspects of their operation will be in a stronger position to benefit themselves-as well as their learners. They should expect to benefit in reputation and through inspection, where equality and diversity is now a limiting grade (see Section 8). From Ofsted, HMCI Christine Gilbert has advised, “For employers and learners alike, when you are next considering what to study and where to take your business – take a look at the equality and diversity judgements in a provider’s inspection report – it may help you make your decision”10. Such choices directly affect the provider as a business.

9 A Flourishing Region: The Regional Economic Strategy for the East Midlands 2006-2020. EMDA 2006 10 HMCI Christine Gilbert, writing in Talisman, No 79, September 2009


How leaders promote equality, diversity and inclusion: findings from the East Midlands research project

6.1 Research was carried out among sector leaders during February and March 2010 to support and inform this Guide. The main factors being investigated in the research were the adoption and establishment of inclusion and equality practices within different education and training organisations. Following consultation with partners, an online survey was created. Full details of those consulted and the findings are in Annex 5.

6.2 The survey combined a series of multiple choice questions with the opportunity for respondents to add individual comments throughout.

While this was an East Midlands-based project, invitations to take part in the research stretched beyond the region as advised by the project partners. The survey was completed by 36 respondents. These included colleges, work based learning providers and community & voluntary sector providers. Twelve of these were at principal or chief executive level, while over half were at director level.

Outcomes of the survey are summarised here, with representative quotes made by the respondents. These, and the research findings, lead to “Action points and considerations” for supporting EDI.

6.3 The survey had a series of key questions / areas in sections, including:

• how actively is your organisation promoting a comprehensive approach to equality and inclusion?

• is there a clear vision for equality and inclusion?

• how well informed about, and committed to, equality and inclusion are key groups in the organisation?

• awareness and application of equality and inclusion

• the main organisational barriers to equality and inclusion

• the organisation’s equality and inclusion success stories.

6.4 For the first of these, the organisation’s activity in promoting a comprehensive approach to equality and inclusion, most respondents (80%) believe their organisations are ‘very active’. Examples were provided of compulsory training, working groups, senior management support and inductions. They also reported this activity as work in progress, with much more still to do.

“In terms of promotion we are doing a lot of work. However, we still have a long way to go to make all our provision effective and inclusive. A lot of work is going on in terms of raising awareness among staff and developing support mechanisms to achieve a truly inclusive provision and environment.”

6. The East Midlands Regional Survey of Providers Leading Equality, Diversity and Inclusion

• Bydevelopingandcompletinganequalityvalue-chain can you identify ‘gaps’ in your chain to be filled in ways that will support your capacity to improve business outcomes, learner outcomes and/or employee outcomes?

• DoesyourprovidermissionhaveaclearEDI focus? Is this linked to your business objectives and associated KPIs?

• Doimprovementtargetsspecifythe needs of different learner groups?

• Haveyouincorporatedalllegalandregulatory requirements for EDI, including those in the Equality Act 2010, into your strategic and business planning processes?

• Areyouabletoevidencethatplanningand allocation processes consider the needs of all groups of learners?

• Dolearningandteaching,pastoralcareand enrichment activities cater to the needs of all learners?

• Docompetencyandstaffperformanceappraisal systems embed EDI objectives that support learner outcomes?

• DoesEDItrainingsupporttheaimsof the organisation and do you assess the impact of training? For example is training tailored to address underachievement of a particular learner group and is the impact measured against progress of associated targets?


Action points and considerations • Howeffectiveistheflowofinformation

about EDI in the organisation to and from all distinct groups?

• Isensuringeffective,two-wayinformationflows on EDI issues addressed in your self-assessment processes and improvement planning?

6.7 The next section of the research sought to clarify the level of commitment by different groups to equality and inclusion. It revealed that respondents believe that boards / governors, managers and teachers are ‘very committed’ to inclusion. However, only half of support staff are described as ‘very committed’.

Results suggest that there is a recognised need to continue building commitment from all staff and stakeholders.

“This is a difficult question to answer as this is an important area of work for the college and I don’t believe any group would state anything but commitment. However human nature being as it is means that some people are probably not going to be equally committed to all parts of equality and inclusion, as some people will have prejudices. The aim we have is to stop a prejudice leading to discrimination.”

Action points and considerations • Whatcanbedonethatwillhelp

build commitment from all staff and stakeholders?

6.8 The following section sought to understand the different interventions that providers are using to encourage an environment of equality and inclusion. 34 out of the 36 respondents confirmed that the organisation provides equality and diversity training for staff. This represented 97%, as compared with 84% that provide such training for learners.

Note: training is the traditional route. Coaching and mentoring approaches are also being used, although, as with training, these are more prominent for staff than for learners.

6.9 Role competencies that encompass inclusion and equality can provide the organisation with the opportunity to monitor and review managers’ performance against these competencies. Just over two-thirds (69%) of respondents indicated that management competencies are in place. Of these competencies, just under two-thirds (64%) include equality and inclusion.

“We are in the process of developing competencies for managers and team leaders. There are elements of competencies which include equality and fairness.”

“We are in the process of developing competencies for managers and team leaders. There are elements of competencies which include equality and fairness.”

Action points and considerations • Whatisyourorganisationactivelydoing

to promote inclusion and equality? • Whatsupportmechanismsareinplace

to support the activities? • Istheentireorganisationfocusedupon

a “hearts and minds” approach?

6.5 The next section sought to identify if respondents believe the organisation has a clear vision for equality and inclusion.

All respondents were unequivocal on this topic – there was 100% agreement that each of their organisations has a clear vision for equality and inclusion.

“This is driven from the top. The principal and vice principal are fully supporting the agenda and are not missing any opportunity to promote E & D. This then results in clarity and shared vision. However please remember that this is a journey and we have still a lot to gain.”

Action points and considerations • HowrecentlyhaveyoutestedoutyourEDI

vision with learners, stakeholders, staff and Board members to confirm that it is clear?

• Supportanddrivefrom‘thetop’isessential.How clear is this support? Does it include the Board as well as leadership team?

6.6 The next section focused on different groups in the organisation. How well informed are they about equality and inclusion? The questions allowed them options from ‘very well’ informed through to ‘not at all’ informed.

Respondents believe that 75% of directors and senior managers are ‘very well’ informed about equality and inclusion. However, this figure falls away when other groups are considered. Only 58% of board members or governors are ‘very well’ informed. The figures are lower for middle (53%) and front line managers (55%). Only 39% of teachers and support staff are considered to be ‘very well’ informed.

The pattern in the findings suggests that the further the group is away from the leadership team, the less likely they are to be ‘very well’ informed. The tendency is to become ‘quite well’ informed.

“We need to do more work on keeping service users up-to-date with the frequently changing agendas. As far as their own experience goes, they are well enough informed to know how to behave and how to complain in an informed way. Partners are informed at different levels – we give them all the same information; they absorb it differently, so we don’t have a consistent picture about their practice.”


“We are stronger in the philosophy than the detail. We have a small team which struggles to address the huge amount of information available, asked for or expected.”

Action points and considerations • Isthereagapinyourorganisationbetween

understanding what needs to be done on EDI issues and ensuring robust processes are in place to turn information into action?

• Howeffectiveisyouruseofdatatodriveimprovement in your EDI indicators?

• Whatareyoudoingtoclosegaps?

6.11 In addition to the multiple choice questions, respondents were invited to describe (unprompted) the main barriers to equality and inclusion in their organisation. These have been summarised into a list, presented below. A range of quotations from respondents is also provided.

“Our monitoring system is not very efficient and some areas in the college are quite complacent in terms of staff not conforming to agreed standards in relation to E & D. This is being dealt with at the most senior level in the college and we are hoping to see some improvements across the board.”

“30% of our students are from BME backgrounds. 10% of our staff are from BME backgrounds I believe positive role models on the staff team will aid improvement - but this is long term.”

“Training does not alter attitudes which are ingrained- sometimes it is very difficult to overcome prejudices particularly in security, catering and secretarial staff who may be on low paid short term contracts yet present the public face for the organisation.”

Table 2: Barriers to equality and inclusion

• Resources • Insufficient and / or inappropriate

funding streams • High level accountability/reporting progress• Tokenistic approach / complacency• Inefficient monitoring • Leadership not role modelling required

behaviours / not walking the talk • Embedding still to be done in curriculum• Greater diversity of the governing body

and senior leadership team is needed• Increasing the proportion of staff from

under-represented groups• Recruitment from traditionally excluded

communities remains low• More sophisticated use of EDIMS needed• Further and better communication

with learners • Lack of cohesion around the EDI agenda

Action points and considerations • HoweffectiveareEDIlearningand

development programmes for staff and learners?

• Doesyourorganisationhaverolecompetencies for staff? If so, do these extend to inclusion and equality?

• Howeffectiveandextensiveareotherinterventions, such as leadership development, coaching or mentoring EDI?

6.10 The next section aimed to create a ‘temperature check’ for the awareness and application of equality and inclusion. It included a number of statements that sought to capture the awareness of such factors as Ofsted and legislative requirements, coupled with the provider’s capability to use data and self-assess effectively.

There are a number of potential messages emerging from the answers, shown in detail in Annex 5. Illustrated in Table 1 is the very mixed response relating to data, evidence and self-assessment. This indicates more focus is required by providers on the performance management, monitoring and reviewing of the data and evidence that is available. There appears to be a gap between understanding accountabilities, for example, through regulation or inspection, and ensuring robust processes are in place to capture key information. While 77% of respondents claim that the leadership team are ‘very’ aware of Ofsted requirements for equality and inclusion, the identification, analysis and effective use of data is considerably less, as seen in the table below. This is a sample of the detail from the survey, which is available in full in Annex 5.

Table 1: Respondents’ answers to questions relating to the use of evidence and self-assessment to promote EDI.

Very Quite Moderately Not at all Don’t know

How effectively does your organisation make 30.6% (11) 47.2% (17) 16.7% (6) 2.8% (1) 2.8% (1) use of the available evidence relating to inclusion?

How well does it identify, gather and use data? 37.1% (13) 42.9% (15) 17.1% (6) 0.0% (0) 2.9% (1)

How effectively do your current self-assessment 45.5% (15) 36.4% (12) 9.1% (3) 0.0% (0) 9.1% (3) procedures identify and assess equality and inclusion issues?


7.1 This Section explores a range of approaches that can be used by providers to strengthen inclusion. Having a clear vision sets the scene, but translating the vision into meaningful actions for staff and learners alike depends upon effective communications and interventions. There are a broad range of approaches that can be developed. The most appropriate for your organisation will depend on your context and the inclusion challenges you face.

7.2 To help put this into context and provide an orientation model, we have created The Inclusion Cycle (below), which illustrates how an organisation can establish a cycle of actions to support an inclusive environment.

The Inclusion Cycle emerged from a ‘rich picture’ exercise carried out by delegates on a Coaching and Mentoring for Equality and Diversity pilot programme, held by LSIS during 2009/10. It is focused upon continuous improvement. While different sections of this Guide cover the topics contained in the cycle in greater detail, it is helpful to bring them together to generate a sense of the ‘whole’.

Development interventions that promote and support inclusion and equality co-exist with all other elements within the cycle. Together they become part of a seamless approach that includes all internal and external stakeholders. If any part of the process is missing or weak, then it affects the rest of the cycle.

7. Approaches to Promoting Equality, Diversity and Inclusion

The Inclusion Cycle

The organisation’s vision & values for

inclusion & equality

Culture of responsibility that engages hearts

& minds

Leadership that includes & inspires all

to do their best

Outward focus built upon relationships, collaboration & ability to engage external

stakeholders

Managers integrate inclusion outcomes with

operational outputs

Robust performance management that

monitors performance & uses evidence

Range of development approaches that support

inclusion & equality

Action points and considerations • Doleadersinyourorganisationexemplify/

model good EDI practices? • Whichofthesebarriersarepartiallyor

wholly within the provider’s control? • Howactivelydoesyourorganisation

challenge any breaches to its vision for inclusion, equality and diversity?

• Howcanmonitoringbetightened and improved?

• Howeffectivelyistheorganisationencouraging inclusion and equality and supporting this with clear compliance requirements? For example, is EDI embedded in job descriptions and staff performance objectives?

6.12 In addition to the barriers to equality and inclusion, respondents were also asked to describe, unprompted, equality and inclusion successes in their organisation. There are good stories to tell. A selection of these is listed in the panel.

Table 3: Equality and inclusion successes, recognised in provider responses

• Students and staff speak very well of equality and inclusion at the college (survey and Ofsted evidence). Have closed the attainment gaps between different ethnic groups

• College systems to challenge any breach or discrimination are effective. Majority of staff and student are well aware of their roles and responsibilities in relation to E & D and organisational expectation of accepted behaviours and practices

• We realise the value of an increased talent pool together with flexible working opportunities and have successfully recruited part time roles through targeted markets e.g. working mums website

• Our Single Equalities Scheme• Make up of staff/students reflect the

local community• Introducing the data sets to curriculum teams

and key support areas. Seeing the evidence is always powerful in starting change.

• Chief Exec champions and leads the E & D Steering Group

• Over the last 9 months the college has invested time and resources in up-skilling staff and giving them confidence. On our MIS system we have introduced an area for staff to record incidents, support discussion relating to E & D.

Action points and considerations What are the EDI success stories for your

organisation? Do you seek them out, utilise them to improve practice, and celebrate them?


• Howpro-activeistheorganisationinestablishing different interventions that can promote inclusion and equality?

• Howeffectivelydoestheorganisationencourage personal accountability for inclusion and equality?

• Areallmanagersasfocusedupon inclusion as they are on other key performance indicators?

• Howeffectivelyisdatabeinggathered,analysed and used?

• Howwellistheproviderrelatingexternallyto stakeholders?

Representative comments from the regional survey (see Section 6) are used in this section, as below:

“In terms of promotion we are doing a lot of work. However, we still have a long way to go to make all our provision effective and inclusive. A lot of work is going on in terms of raising awareness among staff and a developing support mechanism to achieve a truly inclusive provision and environment.”

“We regularly review our working practices and procedures as part of our equality impact assessments, curriculum review, quality review, contractual arrangements with third party organisations and also in the evaluation of the services we provide by learners.”

“Our monitoring system is not very efficient and some areas are in the college are quite complacent in terms of staff not conforming to agreed standards in relation to E & D. This is being dealt with at the most senior level in the college.”

A brief guide to interventions that support inclusion & equality

7.10 Providers are making use of a broad range of interventions to promote inclusion and equality. A number of these approaches are summarised here.

7.11 Training: inclusion, equality & diversity training for staff

Many, if not most, providers offer some degree of inclusion, equality and diversity training to managers, teachers and staff. Sometimes this is compulsory and accredited.

Making the training course mandatory or “expected” ensures that all members receive the chosen training. All members of the leadership team should participate, including the Board and principal/chief executive. If the spirit is positive, energised and supported from the top, then it sets an example for the staff as a whole.

7.12 Coaching. Coaching is an approach that is increasingly being adopted by organisations as a means of raising organisational and individual performance. The Chartered Institute of Personnel and Development (CIPD) 2008 Learning & Development survey estimates that 71% of organisations are using coaching.

The Inclusion Cycle explained

7.3 This is a virtuous, expanding cycle, but there are two initial critical success factors: leadership and vision / values. If these are in place, then everything else flows on from them.

The organisation’s vision & values for inclusion & equality This sits at the heart of inclusion and equality. A vision demonstrates ambition and informs the provider mission.

7.4 Leadership that includes & inspires all to do their best

Leadership and the vision are intrinsically linked. Leadership generates a clear vision and a vision generates effective leadership. The two are inextricably linked, hand-in-glove.

7.5 Range of development interventions that support inclusion & equality

The organisation can introduce a broad range of development interventions – these are explained in detail later in this section.

7.6 Culture of responsibility that engages hearts & minds

Effective leadership approaches can have the benefit of encouraging staff to hold themselves personally accountable. This cuts across all staff whether teachers, managers, administrators or other support staff. At its most effective, staff take personal responsibility for promoting inclusion and equality.

7.7 Managers integrate inclusion outcomes with operational outputs

A challenge for those seeking to champion the inclusion and equality agenda can be those managers whose focus is narrowed by the demands of the operation on a daily basis.

7.8 Robust performance management that monitors performance & uses evidence

As this has a measurement and monitoring role, it is included towards the end of the cycle. But planning to monitor and gather evidence starts long before the first learner applications arrive. This is often the most easily overlooked aspect of the inclusion cycle. Carried out successfully and delivering “real time” information, it can be used not only to enhance performance but also direct future activities.

7.9 Outward focus built upon relationships, collaboration & ability to engage external stakeholders

Last but not least is outward focus; how the provider serves its different communities and works with the different partners.

Action points and considerations • Doestheorganisationhaveaclearvision

for inclusion and equality? To what extent is it communicated to and understood by all?

• Howeffectivelyaretheorganisation’sleaders role modelling and championing inclusive practices?


7.17 Competencies. The formal role expectations of staff in the organisation can include competency sets. These allow the individual’s performance to be effectively monitored and review at appraisals. These competencies may be extended to inclusion and equality. In this approach, it would be a requirement of staff to be competent in inclusion and equality and they could be provided with training and development to enhance knowledge and skills.

7.18 Quality marks. There are a range of externally approved quality standards the organisation can aim for. These will help to bring focus to the subject of inclusion and equality and also provide a source of externally-assessed evidence of the organisation’s position and scope for progress. See Section 10.

7.19 Champions. Many organisations appoint inclusion and equality champions. These individuals can promote best practice. If this route is taken, it is important to ensure that others (especially managers) do not feel they can pay less attention to EDI. Additionally, principals / chief executives-if not the champions themselves- should ensure these individuals are given the opportunity to contribute through their leadership and other related roles.

Action points and considerations • Istrainingforinclusion,equality&diversity

in place for all staff/Board members? Is it compulsory or expected? Is it delivered flexibly to meet the needs of different groups, with its outcomes monitored?

• Aredirectorsandseniormanagersrolemodels for EDI? Do they always attend appropriate inclusion and equality development programmes?

• Aremanagersencouragedtocoachotherson inclusion and equality?

• Mentoringisanexcellentapproachthatmodels successful behaviours to the mentee. How may you utilise it for the benefit of learners and staff in your organisation?

• Howeffectivelydoesyourorganisation’sleadership promote excellence in EDI?

• Whatrecruitmentandinductionprocessesare in place to support inclusion and equality?

• Howvisiblearetheorganisation’sleadersas champions of inclusion?

• WhatEDInetworkgroupsexist? • AreEDIcompetenciesinplaceforallstaff?

Is inclusion embedded in roles through competencies?

• Towhatextentdointerventionssupporta ‘hearts and minds’ approach that embraces inclusion and equality?

• Whatisbeingdonetoinvolvelearnerandemployer groups whose attitudes might be more challenging to inclusion and equality?

• Whatenforcementmeasuresdoestheorganisation take (or is prepared to take) when inclusion and equality approaches are ignored or abused?

LSIS has piloted a programme with the former LSC that combines inclusion, equality and diversity with coaching and mentoring approaches. This 10-day programme is running twice during 2010.

Coaching is defined by Whitmore12 as: “unlocking a person’s potential to maximise

their own performance. It is helping them to learn rather than teaching them.”

Coaching can have a positive impact upon organisational climate and, with its emphasis on questioning / learning rather than telling, can help promote inclusion.

“A significant investment has been made in introducing a coaching culture, but it isn’t yet fully bedded in across the college. Mentoring is offered mostly at management levels.”

7.13 Mentoring. Mentoring can be used for both staff and learners. It has often been used to encourage those from under-represented groups. In this instance the mentor, from the under-represented group, works with the mentee, from the same group. This can build confidence, role-model appropriate behaviours and reduce the risk of the mentee leaving the organisation through feeling unsupported.

However, mentoring can also be provided cross-culturally, with mentor and mentee drawn from different groups. Both mentoring and coaching say to the person being supported: “you matter”.

7.14 Leadership. As considered in Section 3, effective leadership is essential to set the tone and pace for the organisation. Principals and chief executives can take advantage of the Principals’ Qualifying Programme (PQP) organised through LSIS. Leading an organisation that promotes inclusion and equality is encouraged on this programme. There are also other sources of development and support (see Section 11).

7.15 Network groups. The establishment of network groups is, in itself, inclusive. This can be particularly effective for large and complex organisations or those located around multiple sites.

7.16 Working groups. A powerful way to focus upon inclusion and equality is to establish a cross-organisation working group. Ideally this would be populated by people the length and breadth of the organisation, including those from traditionally under-represented groups. It is helpful if the principal / chief executive or director attends as a champion, or a Board member where appropriate. It sends out a strong signal to the organisation of the importance of EDI.

“We invest a lot in the agenda and involve all staff in some way. We have a steering and monitoring group which has representation from across the college, including students and a governor. All staff have had training in some E & D aspects in the last two years.”

12 Whitmore.J., 1996. Coaching for Performance. 2nd Ed. London: Nicholas Brealey Publishing.


8.6. If it is unsurprising that the key to high performance is good leadership then one of the best leadership tools is effective self assessment. The LSC and LSIS published generic guidance on this in September 2008 (Self assessment: Updated Guidance for the Further Education System) and specific guidance for EDI in October 200914. The latter document provides information on policy and practice. Its development was informed by the creation of Ofsted’s new Common Inspection Framework (CIF) in 2009, which is referenced in chapter 3 of the guidance on self assessment of equality and diversity.

8.7 The 2009 CIF “raised the bar” for sector leaders in several senses. Most importantly for the purposes of this Guide, it set raised expectations for equality and diversity. The 2009 inspection framework states that there will be a single judgement on equality and diversity, which will include social and educational inclusion. A common grading scale continues to be used in making judgements: Grade 1, outstanding; Grade 2, good; Grade 3, satisfactory; Grade 4, inadequate. Limiting grades are introduced and these are considered as part of the assessment of leadership and management before the overall effectiveness judgement is made. Limiting grades relate to safeguarding, and equality and diversity, as these are considered to be essential in assuring the quality of the development and well-being of young people and adults. The grades for these two aspects may therefore limit other grades, including the grade for overall effectiveness.

8.8 In response to national developments and legislative changes, revisions to the inspection framework on evaluating outcomes for learners now also includes greater emphasis on whether learners feel safe and, where relevant, how well they develop skills, knowledge and understanding relevant to community cohesion and sustainable development. The continued spotlight on the promotion of equality and diversity now has greater emphasis – with inspectors judging how well providers identify and narrow achievement gaps between different groups of learners to help ensure that all learners fulfil their potential.

8.9 The CIF is supported by Ofsted’s Handbook for the inspection of further education and skills from September 2009 (see the Ofsted website: reference b090105). Judgements relevant to the grading of equality and diversity are found in the leadership and management section, C; explicitly in C4 (see accompanying text box). However, colleges and training organisations should take account of all the leadership and management section in the current context. The other questions, if evidenced positively, will address the vision and direction elements of leadership of EDI as well as take account of the related limiting grade, for safeguarding.

14 Equality and Diversity in Self-Assessment: Guidance for Colleges and Providers, LSC and LSIS October 2009.

8. Inspection and Performance Management

8.1 This section of the Guide looks at inspection and performance management as they affect the leadership of EDI in a college or training organisation. It is not the intention to duplicate all the guidance available from Ofsted or that covering the Framework for Excellence, which to date has been the government’s performance management system for post-16. Links to these sources are shown here, with key issues and action points arising from them.

Inspection

8.2 It is widely understood in the sector that responsibility for quality and improvement lies with each individual provider. External inspection and performance management arrangements may support providers’ own processes or enable intervention where necessary.

8.3 The overall aim of inspection is to evaluate the efficiency and effectiveness of the provision of education and training in meeting the needs of learners (the last five words are crucial in the judgements made). As Ofsted has noted, a key driver for improvement is “leadership which promotes very high standards in a positive and supportive culture that aspires to excellence”13.

8.4 The major changes introduced by Ofsted in 2009, for equality and diversity assessments, are addressed below. In its most recent Annual Report, for 2008-9 (www.ofsted.gov.uk/publications/annualreport0809) Ofsted noted with regard to colleges that “there is a close link between the judgements for leadership and management, overall effectiveness and the capacity to improve. Leadership and management were good or outstanding in 65% of colleges inspected, demonstrating clear strategic vision, a strong focus on raising achievement, accurate self-assessment and rigorous college-wide quality improvement. Equality of opportunity is good or outstanding in 76% of cases. The best colleges promote community cohesion well…” (paragraph 138).

8.5 With regard to the diverse work based learning sector, which includes providers of apprenticeships, Train to Gain programmes and Entry to Employment, Ofsted’s Annual Report noted that the vast majority of good or outstanding providers in 2008-09 were specialist providers or employers with provision in one or sometimes two sector subject areas. The robustness of self-assessment tended to be weaker in this sector than in colleges. There were also more providers where safeguarding procedures were not meeting current requirements.

13 How Colleges Improve, Ofsted, Sept 2008


Another recent inspection report showed how good leadership, delivery and learner outcomes can come together to produce outstanding results.

South Birmingham College was judged Outstanding (Grade One) for Leadership and Management and the contributory grades of safeguarding and equality and diversity at its inspection (report published April 2010).

Inspectors noted that:

“Leadership and management are outstanding. Large numbers of students come from educationally disadvantaged backgrounds; but a strong ethos of inclusion, raising aspiration and supporting individuals to achieve, passionately supported by governors, managers and staff, results in high success rates. Demanding targets are set and met…”

8.11 Capacity to improve: Evaluative statements To make their judgements, inspectors will

evaluate the extent to which: • the provider has a sound track record of

sustained improvement • the provider sets and meets ambitious

targets to improve outcomes for all learners

• the provider has a clear vision and appropriate priorities that will sustain improvement and raise expectations for all users

• governors or the appropriate supervisory body fulfil their duties and ask challenging questions to raise or maintain high standards and secure positive learner experiences and outcomes.

The action points below relate to the relevant questions on leadership and management. Full details of Ofsted’s expectations for leadership and management, along with evaluative statements and grade characteristics, may be found in the Inspection Handbook (from page 60).

Action points and considerations: • Howeffectivelydoleadersandmanagers

raise expectations and promote ambition for EDI throughout the organisation?

• Howeffectivelydoyourgovernors/supervisory body provide leadership, direction and challenge to EDI?

• Areyourgovernors/thesupervisorybodydirectly involved in EDI leadership? Does their provider mission set expectations for EDI? Do they set standards and approve key performance indicators? Did they approve the Equality Scheme(s)? Do they monitor its effectiveness, providing direction and challenge?

• Doyourgovernors/thesupervisorybodyreview the quality and standards of provision to ensure that EDI objectives are being attained?

• Areleadersandmanagersatalllevelsofyour organisation engaged in planning EDI objectives and in self-assessment of progress made?

Ofsted and Inspection

In more detail, the equality and diversity grade will contribute to and may limit the grade for overall effectiveness in the following ways:• where a judgement of inadequate is awarded

for equality and diversity it is most unlikely that the overall effectiveness of the provider will be better than satisfactory. It is likely that the overall judgement will be inadequate.

• where a judgement of satisfactory is awarded for equality and diversity it is most unlikely that the overall effectiveness of the provider will be better than good.

If a provider cannot demonstrate that it is working within the two operating principles this should prompt a judgement of inadequate for equality and diversity. The two operating principles for the inspection of equality and diversity are:• how effectively a provider is narrowing any

achievement gap between groups of learners• how effectively a provider actively

promotes equality and diversity and tackles discrimination.

8.10 There is evidence in some inspection reports in 2009-10 of how the new approach to EDI is working.

One large college received the following grades: Overall Effectiveness, 3; Leadership and Management, 3; Equality and diversity, 3.

The text of the report read: “The college actively promotes equality and diversity and effectively tackles unfair discrimination. The performance of different groups of learners is analysed and gaps in performance identified. There is an achievement gap between the college success rate and that of black learners, those from minority ethnic backgrounds and learners from certain vulnerable groups in 2009”.

The issue here was the achievement gap.

A medium to large training provider received the following grades: Overall effectiveness, 2; Leadership and Management, 2; Equality and Diversity, 3.

The text of the report read: “Equality and diversity is satisfactory. Despite many newly introduced materials and initiatives since the previous inspection, staff do not sufficiently reinforce equality and diversity during training and progress reviews… (The provider should)… ensure aspects of equality and diversity are better reinforced and explained in the context of learners’ work during formal progress reviews and training…”

The issue here is the expectation that actions taken are understood by learners, who benefit as a consequence.


How effectively does self-assessment in EDI improve the quality of your provision and outcomes for learners?

• Doyourself-assessmentprocessandreport include full coverage of equality dimensions and a summary judgement/assessment?

• Doyourgovernors/thesupervisorybody‘sign off’ the self-assessment report? If so, is there a statement to the effect that they are confident that the organisation is fulfilling its statutory, legal and contractual obligations in regard to equality?

• Isthereaseparatesection/overviewandjudgement that evaluates how well/effectively the organisation is implementing equality, tackling unfair discrimination and promoting the benefits of diversity and, where applicable, how it is positively contributing to community cohesion?

Note; for more on self-assessment see reference 14, cited in paragraph 8.6.

How efficiently and effectively do you use your available resources to secure value for money?

• Isaccesstolearningresourcesavailabletoall learners, regardless of their background, and appropriate for effective study in lessons and for independent study?

• Arethereresourcesthatallowalllearnersto participate equally, regardless of their backgrounds or circumstances?

• Dowork-basedlearnershaveaccesstogoodlearning materials, equipment and facilities?

• Dolearnerswithlearningdifficultiesand/ordisabilities have appropriate specialist staff and specially adapted learning resources?

Performance Management: Equality Schemes and Impact Measures

8.12 The LSC expected those providers that it funded which were public bodies to have Equality Schemes. This included FE and 6th Form colleges. The Single Equality Scheme (SES) model was encouraged by the LSC. Private providers were also encouraged by the LSC to have Equality Schemes although this was not a legal requirement. Again, the SES model was recommended, rather than individual schemes for race, gender and disability. The LSC had its own organisational SES, subsuming all three statutory schemes for a public body.

The statutory equality duties on the LSC’s successor bodies have not reduced with the machinery of government changes. In fact, they have been increased by the requirements of the Equality Act 2010.

8.13 In 2009 the LSC commissioned a review of the operation of its SES, by ECOTEC (Review and Evaluation of the LSC’s Single Equality Scheme, June 2009). This review went on to consider the LSC’s effectiveness in addressing equality. The findings have value, by implication, for providers as well as for the LSC’s successor bodies for planning, commissioning and funding: the YPLA, Skills Funding Agency and Local Authorities.

• Whatequalityanddiversitymeasures do you use to assess the effectiveness of leadership and management with regard to EDI?

• IstheimportanceofEDIfortheorganisationcommunicated effectively to all staff, learners and external partners/stakeholders?

How effectively do you promote the safeguarding of learners?

• Doyouhavestrategiesinplacetosafeguard all learners- including those such as apprentices who are based with employers- from harassment, bullying and discrimination?

• Doyouconsiderequalityanddiversityaspart of health and safety risk assessments, in particular for vulnerable learners?

How successful are you in actively promoting equality and diversity, tackling discrimination and narrowing the achievement gap?

• Whatisyourunderstandingof“activelypromoting” equality and diversity? Do all your staff and governors/Board members understand their roles in this?

• Howactivelydoyoupromoteequalityofopportunity? What EDI data do you utilise for learners and staff in doing this? How do your internal and external communications assist achievement of this goal?

• Howdoyouacttoeliminatediscrimination? How do you monitor the effectiveness of this activity and use the results for improvement?

• Howdoyouassessoutcomesfordifferentgroups of learners. And more importantly how do you instigate and monitor the impact of actions designed to drive improvements?

• Whatactionistakentoensurethattheethnic profile of staff and governors broadly reflects that of the learner population - and local population where this fits with your mission?’

How effectively do you engage with users to support and promote improvement in EDI?

• Doyouhaveaneffectivelearnerinvolvement strategy? Does it work well with all types of learners and all modes of attendance in your organisation? How is it utilised to engage learners in achieving EDI objectives?

• Howarestaffatalllevelsofyourorganisation engaged in achieving EDI objectives? Are they provided with induction training and continuing professional development in EDI issues?

• Arevisitors,contractorsandthepublicmade aware of your EDI values and goals and engaged in supporting them?

• Howwelldoesyourprovisionservetheneeds of socially excluded learners and potential learners? What measures are you taking to improve their representation and success?


“There was a prevalent view… that the degree to which providers effectively self-regulate in terms of equality is extremely variable.

Research participants identified a number of barriers to effective equality self-regulation within some providers. These included that providers did not always have the desire to address equality because they were more concerned about meeting their funding conditions to ensure their future survival, or their infrastructure was not sufficient to meet these regulatory requirements. Wider concerns about meeting funding conditions were expressed both internally and externally, suggesting that the LSC concentrates only on outcomes that are measurable and that this creates tensions within provision.

Providers have to achieve successful outcomes to receive funding and therefore some providers’ natural inclination was to consider engaging less challenging learners. Though difficult to evidence, this was certainly a prevalent fear articulated by providers. Views were also expressed that larger colleges did have the resources to be able to self-regulate; however, it was the smaller providers who required increased support, as without this they were unlikely to be able to fully meet their equality and diversity requirements. (p16)…

Many interviewees highlighted the difficulty which the LSC has experienced in challenging employer perceptions or behaviour regarding equality, particularly with regard to disability (p17)….”

Action points and considerations • DoyouhaveaSingleEqualityScheme,

or separate equality schemes, that meet your legal, regulatory and contracting requirements as a provider?

• Areyoureviewingyourequalityscheme(s)in the light of the new Equality 2010?

• DoesyourSESoralternativeleadtoactions and measures that enable you to meet your duties and develop good practice in EDI?

• Ifyourworkrequiresthesupportofemployers, how do you ensure that they meet your expectations on EDI issues?

• Aretherebarrierstoyourcapacitytopromote equality and diversity, tackle discrimination and narrow the achievement gap? How are they being addressed?

• Arethereparticulargroupsoflearnersin the communities you serve who you believe to be at risk of disadvantage? What actions are you taking, on your own or with other providers?

8.14 The full ECOTEC review involved an audit and meetings with LSC staff and stakeholders. The main findings included a consideration of the LSC’s equality requirements on providers and are made use of here from that perspective. Positively, the LSC was seen as being at the forefront of EDI and as a good role model for the sector. A regional approach was evident, encouraging localised practice.

8.15 In terms of the impact of the LSC’s SES, a number of concerns were found. Those most relevant to providers at the present time include: a focus on traditional strands (gender, race, disability) when wider EDI issues are evident- and now part of law; the limitations of powers of the LSC to really hold providers accountable, which might be a concern of the successor commissioning bodies as well; the effectiveness -or otherwise- of equality and diversity impact measures (EDIMs); and the need for a greater understanding of how an employer-led approach to skills and training provision impacts on different groups of learners.

8.16 There were two other findings which are relevant at a time of substantial change in planning, commissioning, funding and delivering provision. These were that a) the LSC did not have enough power to influence providers directly with regard to equalities; and b) The LSC’s work in the sector could be affected by policies which seem to prioritise performance targets over equality issues.

8.17 Some key findings from the review which may resonate for colleges and training organisations are detailed in the accompanying text box. They include:

• the positive value of equality schemes as the principal planning document(s) for leading equality and diversity

• the variability of the sector’s response to EDI issues, due to perceived administrative barriers as well as infrastructure issues affecting capacity

• the key driver of funding and its effect on provider behaviour.

In addition the review found, among its respondents, a concern for particular groups at risk of disadvantage, including over-50s and white working class communities.

Review and Evaluation of the LSC’s Single Equality Scheme, June 2009).

“Equality schemes are, in the main, an organisation’s principal planning document for meeting equality related issues in service delivery and employment. At their heart should be a series of actions designed to meet its various duties in relation to race, gender and disability while at the same time proposing ways to eliminate discrimination on the grounds of age, sexual orientation and religion or belief. In addition, equality schemes must also respond to technical issues which emerge from the differing wording of equalities legislation and the accompanying general and specific duties” (p4).


8.21 The FfE was subject to a single equality impact assessment (SEIA) in 2008 and the recommendations were taken into account in planning the Framework for 2009-10. One of them was that the LSC should design and test a performance indicator that takes into account the impact providers have on social cohesion and their promotion of equality and diversity (including as an employer). In response, the LSC set out to scope the introduction of an indicator to measure social and educational inclusion. It is expected that this work will be taken forward during 2010-11. The responsiveness to learners indicator was also developed further for 2009-10.

8.22 The SEIA also noted that the use of priority learning as a Framework filter was in line with Government policy, but recommended that the LSC should continue to monitor the equality and diversity implications for learners excluded from contributing to Framework measures by this approach. In its response, the LSC said it would continue to monitor the equality and diversity implications of learners excluded from contributing to Framework measures. It also committed to undertaking a Single Equality Impact Assessment initial screening in May 2010. From April 2010 equality assessment work has become the responsibility of the Skills Funding Agency.

New measures and evidence sources are also being developed for the FfE. These include long term goals of learners with complex learning needs.

8.23 In the year ahead, the capacity of the Framework to provide top-level grades and scores with drill-down data for colleges and training organisations should assist the effort to narrow achievement gaps and improve outcomes for all learners. It is intended that FfE results and other relevant data will be presented in a “labelling” format. This is described in the Skills Strategy15 as follows: “Drawing on the Framework for Excellence data, all training will be covered by public “traffic light” information, providing quality assured data about performance at course and institutional level…” (p61).

8.24 The new “Overarching Framework for the QA System”16 notes that presentation of performance data will reflect providers’ wider achievements in supporting participation and the community, as envisaged though the development of a “balanced scorecard”. This is the type of tool the FfE can provide, perhaps supplemented at provider level by appropriate local indicators chosen by providers themselves. It should be noted that plans for the FfE may be subjected to change by the government, as it develops its own policies in this area.

Action points and considerations • Ifyouareaprovideralreadyinscope

or due to come in to scope for the Framework- how do you utilise FfE scores in promoting equality and diversity and narrowing the achievement gap?

15 Skills for Growth: The National Skills Strategy. BIS, 200916 The Quality Assurance System for post-16 education and training provision. DCSF and BIS, 2010

8.18 With regard to equality and diversity impact measures (EDIMs), the review reported an over-riding sense of disappointment in EDIMs expressed by the LSC and indeed providers themselves. Many key stakeholders felt that though EDIMs could demonstrate direction travelled they lacked the ‘teeth’ to be able to truly drive or stimulate change in provider behaviour. Furthermore, it was felt that national and regional EDIMs (in the regions where these existed) were often irrelevant to providers and their specific demographics. There were, however, some positive examples of a LSC region using funding to incentivise those providers who were performing well in relation to learners with learning difficulties and/or disabilities, through funding for dissemination of good practice.

The LSC’s successor bodies may take account of these views.

Action points and considerations • HowdoyouutiliseEDIMsinyour

organisation’s response to EDI issues? In particular, to improve outcomes for all learners?

• DoyoudiscussyourEDIMswithyourfunding/commissioning body and other stakeholders?

• AreyouplanningtoreviseyourEDIMs in the light of the Equality Act 2010.

Performance Management: The Framework for Excellence

8.19. The Framework for Excellence (FfE) was developed as the government’s performance assessment framework for post-16 learning. There has been a plan to apply it to all providers from September 2010, including school sixth-forms, which receive 16-18 Learner Responsive, Adult Responsive or Employer Responsive funding from the Skills Funding Agency, the Young People’s Learning Agency (YPLA) or Local Authorities. The FfE was commissioned by the Department of Business, Innovation and Skills (BIS) and by the then Department for Children, Schools and Families (DCSF).

8.20. The FfE is formed from a set of verifiable performance indicators that give an overall picture of performance for all providers. In this way, the FfE gives an independent, quantitative assessment of the performance of individual providers and of the whole sector against a set of national standards, which will allow a transparent comparison between all providers. The performance indicators for 2009-10 are shown in a table in Annex 6. Providers may find that the three indicators for Learner Success Rates, Learner Views and Learner Destinations-all of which are to be published- will be of most direct value in developing their own suite of comparable, standardised EDI evidence.


• increase in Additional Learner Support budget to support the sector to narrow the attainment gap

• Education Maintenance Allowance (EMA) budget re-directed to support an additional 80,000 learners.

The priorities for young people are summed up as being: participation, attainment and progression.

9.4 As examples of the focus on increasing participation, growth funding in regions (after consolidation of the previous year’s learner numbers) will relate to the number of NEETs in that region. Additional Learning Support (ALS) in 2010/11 is extended to cover all Foundation Learning provision, including former Entry to Employment provision. ALS is targeted at those with the lowest GCSE points scores in English and Maths, with increased resources for them. Diploma learning receives a10% uplift in funding. Given its availability at three levels, its partnership-based delivery model and the trajectory to a full curriculum offer by 2013, the Diploma may be utilised to address local EDI issues.

9.5 Funding for apprenticeships for young people increased by 12.2% in the Statement of Priorities with 21,000 additional places and may be further expanded; see the footnote to paragraph 9.3. The LSC published research on inequality issues in apprenticeships in 200918, also noting good practice in extending apprenticeship opportunities.

The National Apprenticeship Service (NAS) is conducting pilot programmes during 2010 aimed at improving the diversity of apprenticeships.

The strategy is that all suitably qualified young people are to have access to an apprenticeship in one of two chosen sectors by 2013. There is a move towards 1 in 5 young people undertaking an Apprenticeship by 2020.

The focus for apprenticeship funding is on 16-19 and then to 30. However, there is a 3% reduction in funding for adult apprenticeships and a 10% reduction in rates for 25+ apprenticeships.

9.6 Funding for Foundation Learning is being consolidated, with no separate allocation for Entry to Employment (e2e) programmes, with progression routes to be enhanced to Level 2. Functional Skills programmes are intended to support this type of learning as well as higher level programmes.

9.7 The SoP recognises that direct forms of support for young people are important in raising participation. As well as national support through EMA and Care 2 Learn, the SoP identifies support for travel through local authorities. Improved information, advice and guidance (IAG) is to be promoted.

9.8 A Common Application Process from Y11 is to be in place from 2011. This is seen as enabling equality of access.

18 Addressing Inequalities in Apprenticeships: Learners’ Views. LSC January 2009

9.1 This Section of the guide looks at issues of funding for provision which are relevant to colleges and training organisations seeking to plan and resource their work in equality, diversity, and inclusion. It is not intended to be a complete guide to public finance for learning and skills, particularly as changes to public sector finances are being planned by the government. Providers will wish to manage budgets on the basis of agreed priorities and allocations for 2010-11 whilst taking account of the emerging changes. Providers are advised to check for updates on funding issues, which may be found on the Skills Funding Agency and YPLA websites: www.skillsfundingagency.bis.gov.uk and www.ypla.gov.uk.

9.2 The sources of funding explored here are the Department for Education and YPLA 16-19 Statement of Priorities and Investment Strategy for 2010-11, and the Skills Funding Agency’s guide to post-19 funding, as known at the time of publication. Some relevant aspects of the funding routed through the Department for Work and Pensions (DWP) are also noted. Providers are urged to seek their own updates on these sources, as a full review of all existing Welfare to Work policies and expenditure has been announced by the government. The plans cited were set in place by the former government.

The Statement of Priorities 2010-11

9.3 The Statement of Priorities17 identifies funding for 2010-11 in the context of the drive towards full age group participation by 2013/15. It also aims to support the narrowing of the attainment gap, so has direct relevance to providers seeking to enhance their work on EDI. In the context of a reduction in some key rates of funding there are increases in the resources provided for priority groups and priority learning. These are identified in the SoP through the Public Service Agreement (PSA) targets to which they relate, several of which are central to the EDI agenda and focus on reducing disadvantage. Note though that priorities may change as the new government establishes its policies, although 16-19 funding has already been said to be protected at previously-planned levels. In the SoP places are guaranteed on learning programmes for young people and participation is set to increase, particularly among those at risk of not being in education, employment or training (NEET).

The headline key facts are: • £443 million (6.2%) increase in

participation funding across the sector • planned Participation for 16 year olds

in 2010/11: 96% • planned Participation for 17 year olds

in 2010/11: 92% • funding for an additional 21,000

Apprenticeship places for young people

9. Funding

17 Note: at the time of writing it is unclear how the additional £150m to deliver 50,000 additional apprenticeship places focused on SMEs, announced by the government in May 2010, relates to the total of funding for apprenticeships.


that learners and potential learners from all groups have a fair and equal chance of access, success and progression.” (Technical Annex K, p94).

Those providers having the mission and capacity to meet the needs of priority learners should find themselves in the position to meet these requirements.

9.13 Adult Funding. The government announced in May that £200m of the original £983m Train to Gain Budget for 2010/11 would be redirected to other Government priorities- in particular a £150m for a further 50,000 apprenticeship places and £50m for FE capital.The £783m still available for TTG will continue to be targeted on meeting the skills needs at levels 1 to 4 with priority being attached to employees without a first level 2 qualification, employees under 25 without a first level 3 qualification and employees with basic skills needs in literacy, numeracy and language. Funding is available for repeat qualifications at level 2 and 3 provided the qualifications are on the list of approved repeat qualifications agreed between the sector skills councils and the Skills Funding Agency. To date, the focus of Skills Funding Agency funding has been on the “critical importance” of skills for economic growth. There is greater focus on using funding for those without prior qualifications (known as ‘firstness’) across all programmes.

Few providers working to support EDI aims would dissent from this but an impact will be felt on those learners seeking re-training who do not meet this criterion. However, the Skills Funding Agency planned to fund “repeat” qualifications (by level) for apprenticeships pre-25, where the need to re-skill was accepted.

The rates reduction for Adult Learner Responsive under earlier Skills Funding Agency plans will affect the offer of many providers. There is a 3% cash reduction overall and the programme weighting for all Skills for Life provision (except target-bearing numeracy) is reduced from 1.4 to 1.2. Train to Gain has a 3% reduction in rates.

9.14 Programmes for the Unemployed (PfU) fundable by the Skills Funding Agency were maintained as a priority up to the General Election but may be expected to be part of the wider Welfare to Work review announced by the new government. There was expected to be significant growth in the scale and range of these programmes during 2010-11. Improving numeracy was another focus for funding. Updated details may be found in the Skills Funding Agency’s Guidance Notes on funding, on its website.

9.15 Regional priorities for funding have been planned. Providers should check their regional economic strategies (the RES), which are being revised in most regions, including the East Midlands.

9.9 Learners with learning difficulties and/or disabilities. Funding for these learners is recognised as a particular issue. There is an emphasis on local authorities exerting budgetary control, during the period of transfer of responsibilities under the 2009 Act. Local authorities must secure appropriate provision for these learners aged 16-19, or to 25 if they have a learning difficulty assessment. The inclusion of more young people with these needs in mainstream learning is described in the SoP as a key priority. With increasing localisation of this provision, providers with access to sufficient expertise, facilities and resources might consider making or extending provision. This would need to be in liaison with the local authority and other partners. Access to apprenticeships and routes to employment are priorities for these young people. Ofsted is due to report on its national review of this provision in July 2010.

9.10 Offender learning. Offenders are vulnerable learners and much effort is being expended to utilise programmes of education for rehabilitation. This provision is funded separately for young people and adults. For learning in youth custody in Prison Service Young Offender Institutions (YOIs), the contract for the education of young people held in Prison Service YOIs (previously held by the LSC) was transferred to the YPLA in April 2010, and from September 2010 these contracts will transfer to “host” local authorities-those where institutions are situated.

The new duties of local authorities towards young people detained in youth custody will therefore commence from September 2010.

9.11 Funding for vulnerable learners has been highlighted above. Colleges and training organisations should consider their mission and expertise in determining whether they could consider making, or extending, provision for vulnerable young people in the future. Commissioning plans for services to 16-19/25 year olds in 2011-12 will be developed in the months ahead by local authorities. Providers should ensure that they are engaged in the supporting processes.

Note: for some vulnerable learners and priorities in skills European Social Funding (ESF) may also be available.

9.12 Commissioning of young people’s learning. The YPLA’s National Commissioning Framework (NCF) for 2011-12 has been referenced earlier. It includes an explicit commitment to ensuring the interests of the learner and operates in a legal framework where equality and diversity are to be promoted. Colleges and training organisations will no doubt wish to ensure that they are clear on the priorities supported by local commissioning and plan their own provision accordingly.

The NCF states that “Local authorities should use commissioning arrangements and evidence- based monitoring to satisfy themselves that learning providers have policies and processes in place to ensure


10.1 This Section of the guide focuses on leadership of staff with regard to equality and diversity. It is not intended as a guide to employment law, for which providers are advised to consult their representative bodies or professional associations. The learning and skills workforce is itself diverse. Providers include colleges and training organisations in the public, private and voluntary/community sectors. Local authorities make some direct provision, as do large commercial enterprises with training arms receiving public funding for such work as apprenticeships or Train to Gain.

10.2 Within colleges and training organisations there will be a diversity of staff roles, in direct teaching/training, in support roles, and operating full time or part time. Some staff will be working in sub-contracted provision, for the quality of which the holder of the public funding contract remains responsible. This includes ensuring the suitability of the staff for the work undertaken.

10.3 The issues covered here do not deal with leadership of staff in itself; this was considered in Section 3. Instead, the focus is on operational leadership of people. The LSC and LSIS guide to equality and diversity in self-assessment previously cited (October 2009) provided details of the work in this area. This should continue to inform sector leaders and the issues raised are not repeated here but updated. The guidance available from LSIS has been extended since that publication and includes a wealth of staff development material available through the Excellence Gateway website: http://www.excellencegateway.org.uk/

Providers as Employers

10.4 Leadership issues for providers as employers have been clarified through the Equality Act 2010. An outline of the provisions of the Act can be found in Annex 1. The employment, equal pay and services, public functions and associations sections of the Act come into force in October 2010. Education (further and higher education) sections also come into force in October 2010. The Equality and Human Rights Commission expects to publish guidance on this in July 2010 (www.equalityhumanrights.com). A draft code of practice is scheduled to be laid before Parliament in January 2011. Providers are advised to check progress with guidance and implementation advice with the EHRC and with their representative bodies, such as the Association of Colleges (AoC) and Association of Learning Providers (ALP).

10.5 Reference has been made earlier to the public sector equality duty under the Act. This takes effect in April 2011 and will affect the criteria utilised by public agencies such as the YPLA, Skills Funding Agency and local authorities in their contracting with providers. This may have indirect consequences for providers as employers and once again leaders in colleges and training organisations are advised to keep track of guidance as it becomes available.

10. The Learning and Skills Workforce

9.16. For Adult Learner Responsive the Skills Funding Agency encourages providers to seek complementary sources of funding, including fees, where the assumption in 2010-11 is of a 50% contribution. Priority learners on appropriate programmes may remain fully-funded at the rate for the year. The ongoing focus is on target bearing/priority provision.

9.17 The funding for 19-24 Learners with Learning Difficulties and Disabilities is channelled by the YPLA to providers via local authorities. Adult LLDD funding rates are protected in 2010-11.

9.18 Some colleges and training organisations work individually or in partnerships on programmes funded through the Department of Work and Pensions. Among other activities the DWP has promoted and supported a welfare to work agenda-now being reviewed- and has EDI goals. It has targeted access to employment in collaboration with the Department of Business, Innovation and Skills regarding skills for employability programmes. Business opportunities may be found for providers in particular regions or locations, or in support of particular programmes: see www.dwp.gov.uk.

9.19 In summary, 2010-11 is likely to see providers re-focusing their work and perhaps an overall decline in some provision, such as some programmes for adults. Providers operating to serve priority learners should still gain access to funding but these priorities are being reviewed. In some cases provision may be most effective when done in partnership or collaboration, for reasons of sharing expertise, building capacity or ensuring the right scale of service.

Action points and considerations • Areyouawareoftheopportunitiestofund

vulnerable learners in your organisation, as described in the Statement of Priorities 2010-11?

• Areyoupreparedforthecommissioningrequirements in the local authority area(s) you serve, with regard to provision for priority groups in 2011-12? The planning of this work will be underway during 2010.

• Haveyouupdatedyourplansinthelightof the revised priorities for funding?


10.10 The Institute for Learning (www.ifl.ac.uk). This is the professional body for teachers, trainers and assessors, across the sector as a whole. It aims to raise the standing of these professional groups and had some 200,000 members in 2009. It has a Single Equality Strategy (2009-14), reviewed annually. This strategy made a full commitment to promoting equality beyond the then-planned 2010 Act statutory duties, aiming to remove discrimination on “any other grounds that cannot be shown to be justified”.

Actions to be taken to promote the strategy include equality work with partners, among which are the groups and forums with which LLUK also works, as shown above.

10.11 In the East Midlands, among the information sources on leadership in this area are EMFEC (www.emfec.co.uk) - a co-sponsor of this guide- and emCETT. EMFEC’s principal activity is the provision of services which inform, support and enhances delivery by providers of further education and training. As part of this, EMFEC operates a Teaching and Learning Network in the region, attended by Advanced Practitioners and Teacher Trainers. Additionally, EMFEC facilitates thriving networks for managers to lead change and improvement in their respective fields: Quality, Staff Development and Human Resources.

The East Midlands Centre for Excellence in Teacher Training, emCETT (www.thelearningchain.net), is one of eleven in England managed by LSIS. It provides a focus on initial teacher training and continuing professional development, specialising in the development of on-line resources. Its provision includes areas such as training for staff working in offender learning, numeracy and aspects of learning difficulty and/or disability.

Other references for guidancePublic Bodies’ responsibilities:

http://www.equalityhumanrights.com/en/forbusinessesandorganisation/publicauthorities/pages/businessesorganisationspublicbodies.aspx

A brief guide to equality in the workplace for employers:

http://83.137.212.42/sitearchive/eoc/PDF/A_brief_guide_to_equality_in_the_workplace_for_employers.pdf?page=20131

Action points and considerations • AreyouawareofyourEDIresponsibilities

as an employer, including those created by the Equality Act 2010?

• AreyouengagedwiththeEDIworkof LSIS, Lifelong Learning UK and the Institute for Learning and, if in the East Midlands, the EMFEC support networks?

10.6 Lifelong Learning UK. In the context of the continuing needs of the sector for support in leading equality and diversity LLUK, operating as a Sector Skills Council, provides detailed advice and engages the sector in developing practice (www.lluk.org.uk). Instances of guidance available through its website include an overview of the importance of diversity in the lifelong learning workforce, and an online equality and diversity toolkit (http://www.sfbn-equality-diversity.org.uk/) available thorough its Skills for Business link. This includes guidance for employers, legislation updates and case studies from both the sector and other employers. LLUK has also published guidance on how to take positive action in recruitment practice. This addresses how employers may act in order to achieve the objective of widening diversity. Positive action may be required to encourage applications from specific groups and equip individuals with the skills they need to compete equally with others.

10.7 LLUK leads or participates in working groups on all main aspects of equality, with details available through its website. These include the Workforce Race Advisory Group, Disability Equality Implementation Group, and Forum for Sexual Orientation Gender Identity Equality in Post-School Education. The Forum is also involved in research to identify good practice in managing the relationships between sexual orientation and inter-faith equality in the lifelong learning sector.

10.8 For 2009-10, LLUK published a revised version of its Workforce Strategy19, which covers all provider types within the sector as a whole. This revision updated the evidence on LLUK’s key priorities: “Ensuring equality and diversity is at the heart of strategy, policy-making, planning and training”, identifying actions taken and sources of support. An essential element in successful leadership in this area is data, which is another key priority for LLUK. The revised strategy document reported on projects to transform data collection and analysis on the sector workforce, with information sources identified.

10.9 On the broader front of advice for employers and leaders in organisations, the Alliance of Sector Skills Councils published a readable equality and diversity strategy for employers in 2008.20 The templates provided in the publication address principles and practice which any provider-or other employer- could adopt. The issue of ensuring subsequent good practice should be addressed though continuing professional development.

19 Implementing the Workforce Strategy for the Further Education sector in England, 2007-12. A Guide for Learning Providers. Revised version, 2009-10.20 Equality and Diversity: A Strategy for Employers. Incorporating the Business Case for Equality and Diversity and Action Planning Templates.Alliance of Sector Skills Councils April 2008


11.5 Workforce issues were addressed in Section 10 and support for these may come from trade unions. The main unions operating in the public sector colleges have substantial experience of equality and diversity issues. For example, the University and College Union (UCU) has a toolkit for implementing the equality duties. It has also published a guide for new staff in the sector which, among other topics, deals with equality and safeguarding issues. The website includes a link to an equality resource centre (www.ucu.org.uk). UNISON represents many support staff in the sector. It has a single equality scheme and representative groups for women, black, disabled and LGBT members, all of which provide advice and support. (www.unison.org.uk)

11.6 With regard to the complex issues underpinning social and educational exclusion, the National Skills Forum produced a significant report early in 2010. Doing Things Differently addressed the importance of skills in improving access to employment for three traditionally excluded groups: black and minority ethnic people, disabled people and offenders/ex-offenders. It considered the benefits to the economy as well as to individuals and provides a number of recommendations. These varied from improved careers education and guidance to changes to funding for skills and tacking the barriers to employment. The report is a useful source of guidance to how improvements may be made in access to skills for these groups. (www.skillsandinclusion.org.uk)

11.7 Colleges and training organisations may benefit from external comparison or benchmarking of their EDI policies, delivery and outcomes. Among the approaches that may be considered is that utilised by the National Centre for Diversity (www.nationalcentrefordiversity.com). This manages the Investors in Diversity standard, for public and private sector organisations. The process of becoming accredited to the standard looks at mission, business aims and organisational culture and seeks to assess the extent to which these lead to improved EDI outcomes.

11.8 Finally, it is worth returning to the question in Section 3: Why should anyone be led by you? If your organisation goes beyond compliance to produce outstanding EDI outcomes in a stimulating environment for learning, work and achievement-everyone will want to be led by you.

A sample of sector representative bodies: The Association of Colleges http://www.aoc.co.uk; the Association of Learning Providers http://www.learningproviders.org.uk; the Association of Land-based Colleges http://www.landex.org.uk; the Association of Specialist Colleges http://www.natspec.org.uk; the Sixth Form Colleges Forum http://www.sfcf.org.uk; and the body representing the larger colleges http://www.157group.co.uk.

11.1 This section looks at sources of support for leaders in the sector developing EDI policy and practice. It is not intended to be comprehensive but signposts some opportunities. LSIS will continue to provide support for the sector with all elements of EDI. The “Leading Inclusion” project which resulted in this Guide is expected to develop a second phase when, among other potential actions, work will be done to assist the sector in meeting the requirements of the Equality Act 2010. The planning for the second phase includes co-working between the YPLA, EMFEC and LSIS.

11.2 Public and private agencies have been referenced throughout the Guide for particular aspects of EDI. At such a time of change in public policy and its delivery, information supplied directly by government departments and agencies should be the first source. Sector representative bodies such as those contacts listed at the end of this section will advise and interpret policy for their members.

11.3 In addition to these bodies, and others such as Lifelong Learning UK (www.lluk.org.uk) and the Institute for Learning (www.ifl.ac.uk) referred to previously, there are organisations representing specific groups within the sector. These include the Network for Black Professionals (www.nbp.org.uk) which works for race equality in the learning and skills sector; and the Women’s Leadership Network (www.wlnfe.org.uk), which aims to ensure equality of opportunity for women leaders in FE. The Disability Equality Implementation Group, referenced earlier, focuses on disability equality in the lifelong learning sector workforce throughout the UK. Details of its work may be found via the LLUK website.

11.4 The majority of learners in the sector are adults. NIACE remains an outstanding source of advice and guidance for adults in learning and the providers of services for them (the National Institute of Adult Continuing Education: www.niace.org.uk). The work done by NIACE on the needs of particular adult learners includes guidance and research in areas such as the learning needs of carers; race equality; learning difficulties and disabilities; learning and health, including mental health; and safeguarding. NIACE encourages the sector to listen to learners themselves through, for example, its NIACE Voices publications.

11. Sources of Support


12. List of Annexes

Note: These have been published separately by LSIS. It is expected that these will be updated periodically and additional annexes will be published, for example, on sources of support on implementation of the Equality Act 2010, once these become available.

Annex 1: Equality Act 2010: Summary

Annex 2: Beyond prejudice: inclusive learning in practice. Smith V and Armstrong A, LSC/NIACE/LSDA 2005. Inclusive learning principles and checklist.

Annex 3: Organisational Culture: Further text.

Annex 4: The Equality Diversity Value Chain as applied to the learning and skills sector.

Annex 5: The East Midlands Regional EDI Survey 2010 in detail.

Annex 6: The Framework for Excellence Performance Indicators for 2009-10.

We wish to acknowledge the significant contribution to this publication and the ongoing support for the Leading Inclusion Project of the following colleagues. The Core Project Team: Authors:Jim Aleander, lead authorJamila AstromKeith NelsonSaheema Rawat Jamilah Shah, leading inclusion project director, YPLA. Margaret Adjaye, head of equalities and diversity, LSIS. Simon Feneley, deputy chief executive, EMFEC. Alison Scott, continuous professional development manager, EMFEC.

Lead Sponsors:LSIS, Yvette Adams, executive director, organisational development.YPLA, Mick Brown, regional director, East Midlands.EMFEC, Jennie Gardiner, chief executive.

Contact details for leading inclusion project

Margaret Adjaye, head of equalities and diversity Learning Skills Improvement Service4th Floor, Friars HouseManor House DriveCoventryCV1 2TE

[email protected] 024 7662 7900www.lsis.org.uk

Simon Feneley, deputy chief executiveEMFECRobins Wood HouseRobins Wood RoadAspleyNottinghamNG8 3NH

[email protected] 0115 8541617www.emfec.co.uk

Jamilah Shah, leading inclusion project director Young People’s Learning AgencyEast MidlandsMeridian EastMeridian Business ParkLeicesterLE19 [email protected] 0116 228 1954www.ypla.gov.uk

13. Acknowledgments and Contacts

A Guide to Leadership of Equality, Diversity and Inclusion in the Learning and Skills Sector

In respect of its culture and values, LSIS aims to be a high-performing organisation with a passion for learning and a dedication to being led by the needs of the sector. It is committed to promoting inclusivity – as an exemplar resource and catalyst for equality and diversity across the sector.

The Young People’s Learning Agency (YPLA) is committed to Championing Young People’s Learning and to promoting equality, diversity and inclusion. Working with partners the YPLA supports commissioning decisions for provision of learning to all young people by promoting their needs.

EMFEC wholeheartedly supports equality of outcome, believing that individuals should be treated with fairness and respect and empowered to have choice and control. The diversity of individuals is acknowledged and personal characteristics such as background, culture, personality and work-style are respected, in addition to the characteristics protected under equality legislation such as race, disability, gender, age, sexual orientation and religion and belief.

Disability equality policyLSIS is committed to promoting equality for disabled people and we strive to ensure that all our communication and learning materials are available in various formats including large font, audio or braille.Please contact us at [email protected] or 024 7662 7953 quotingthe document reference number to request an alternative format.

Friars House, Manor House DriveCoventry CV1 2TEt 024 7662 7900e [email protected]

LSIS232

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Leading inclusion