Corporate report

Action Plan: March 2023 to December 2024

Updated 13 November 2024

CMA equality, diversity and inclusion action plan

Our Equality, Diversity and Inclusion Strategy 2020 to 2024 describes how equality, diversity and inclusion are essential to the way that we operate, both as the UK’s competition authority and as an employer. As a competition authority, we help people, businesses and the UK economy by promoting competitive markets and tackling unfair behaviour. We need staff from diverse backgrounds to help ensure we make sound decisions that are representative of the different perspectives within society. We also seek to positively influence the approach of the stakeholders we work with, where we can.

As an employer, we remain committed to promoting equality and diversity amongst our workforce. We take steps to ensure we are a great employer that values and welcomes the different ideas, skills, behaviours and experiences of our colleagues. We also aim to foster a culture that promotes wellbeing and mental health and provides support so all our colleagues can thrive.

This action plan outlines how we will deliver the final 2 years of our 4 year EDI strategy.  We will be focusing on:

• recruitment and ‘growing our own’
• career progression and development
• improving senior representation
• pay and reward
• promoting a culture of inclusivity.

Within this we will be prioritising some top actions where we will particularly focus our energy to make the most difference, our ‘Accelerators’.

We all want to work in an inclusive environment, and the Board, Executive and Chief Executive are committed to our ambitious yet achievable plans that will deliver change, not just in our gender and ethnicity pay gaps, but more broadly so the CMA is a truly inclusive and representative place to work.

To deliver our Equality, Diversity and Inclusion Strategy 2020 to 2024, we have developed this detailed 2 year action plan to ensure we remain focused on the right things in the remaining 2 years of our strategy. Our action plan will give us flexibility and agility to adapt our approach if required to meet our longer-term strategic Equality Objectives. This will ensure that initiatives are fully and effectively embedded, our people are engaged and the impact is clearly measured.

Our 5 thematic areas:

• Recruitment and grow our own
• Career progression and development
• Improving representation
• Pay and reward
• Culture of inclusivity

Image description: A decorative image containing the 5 thematic areas above.

In developing our latest 2 year Plan we undertook a CMA wide engagement programme to test thinking, gather views and gauge responses to current initiatives and new opportunities. Our assessment tested whether they help to:

1. reduce one or both of the ethnicity and / or pay gaps

2. improve diverse representation

3. improve our culture of inclusivity and potentially aid retention

4. reduce / mitigate / remove bias

Initiatives were also assessed against the timeframe to achieve implementation, the potential impact of the proposed actions and the level of complexity of delivery.

We have identified a group of actions, our Under the Equality Act 2010, we have a legal duty as a public body to have due regard to the need to promote equality of opportunity, eliminate unlawful discrimination and foster good relations between those who share a protected characteristic and those who do not share it. These include age, disability, sex, race, religion or belief, sexual orientation, gender reassignment, pregnancy and maternity.

We are determined to do more than just meet our statutory obligations. The CMA is determined to build a diverse and inclusive workforce, including at senior levels, that reflects and understands the public we serve. Diversity of experience and thinking is also critical to delivering the best outcomes we can.  Building upon the work we have already done with our staff and our Networks, particularly our Carers, VisAbility, Race, Rainbow and Women’s networks, our renewed action plan outlines what we intend to achieve through to December 2024, building upon our successes and lessons learned.

Our Networks provide valuable challenge and resources to help deliver our strategy and drive our action plan forward. And we’re committed to supporting colleagues in volunteering to play an active role in delivering our E, D and I strategy.

Our 3 Equality Objectives as outlined within our Equality, Diversity and Inclusion Strategy 2020 to 2024 are:

1. Building a diverse and inclusive workforce that reflects and understands the public we serve.

2. Ensuring all colleagues are valued and can contribute to our success.

3. Empowering and enabling all colleagues to thrive and prosper.Accelerators, which will ensure we focus on those initiatives that will deliver rapid progress over the lifespan of this 2 year plan. A thread running through all of our work is ensuring all activities work towards tackling bias and embedding an inclusive culture.  We will challenge ourselves further by shaping a set of meaningful targets to improve the diversity of our organisation.

The following slides set out achievements from the first 2 years of the strategy and focus on the activities within the new plan – these will be developed into projects with meaningful measures to help us to make real progress.

Our equality objectives

Under the Equality Act 2010, we have a legal duty as a public body to have due regard to the need to promote equality of opportunity, eliminate unlawful discrimination and foster good relations between those who share a protected characteristic and those who do not share it. These include age, disability, sex, race, religion or belief, sexual orientation, gender reassignment, pregnancy and maternity.

We are determined to do more than just meet our statutory obligations. The CMA is determined to build a diverse and inclusive workforce, including at senior levels, that reflects and understands the public we serve. Diversity of experience and thinking is also critical to delivering the best outcomes we can.  Building upon the work we have already done with our staff and our Networks, particularly our Carers, VisAbility, Race, Rainbow and Women’s networks, our renewed action plan outlines what we intend to achieve through to December 2024, building upon our successes and lessons learned.

Our Networks provide valuable challenge and resources to help deliver our strategy and drive our action plan forward. And we’re committed to supporting colleagues in volunteering to play an active role in delivering our E, D and I strategy.

Our 3 Equality Objectives as outlined within our Equality, Diversity and Inclusion Strategy 2020 to 2024 are:

1. Building a diverse and inclusive workforce that reflects and understands the public we serve

2. Ensuring all colleagues are valued and can contribute to our success

3. Empowering and enabling all colleagues to thrive and prosper

Recruitment and growing our own

The CMA is determined to build a diverse and inclusive workforce, including at senior levels, that reflects and understands the public we serve. Diversity of experience and thinking is also critical to delivering the best and most impactful outcomes we can.

Diversity has many facets including those protected characteristics as defined by equality legislation, but also encapsulates differing educational backgrounds, personality types, skills, cultural references and experiences.

We have already put in place a range of initiatives which we will continue to deliver over the next 2 years. Examples include:

• We have developed our analysis of recruitment activity to understand the diversity profile at key stages in the recruitment process.
• We use the Success Profiles Framework for recruitment, where candidates are assessed against a range of elements including technical skills, experience and behaviours that would be expected for their role.
• All recruitment campaigns have structured interview plans to ask questions about role competency, ensuring that questions are fair and not biased.
• All SCS and grades AO to Grade 6 interviews have diverse gender panels, wherever possible.
• We facilitate monthly hiring manager training which covers a range of topics designed to support recruiting a diverse workforce.
• We promote our staff networks to potential applicants via online methods (for example, on LinkedIn) and via the job application system.

Our future plans for 2023 to 2024

Over the next 2 years our Accelerators are:

1. To review our entire recruitment process to identify and address the potential barriers that applicants might currently face.

2. Implement and operationalise diversity representation targets to be achieved over a specified period. Our achievements against our targets will be published internally and externally.

3. Build our “Grow Our Own” programmes.

We also expect to:

• Review what behaviours we are asking new applicants to demonstrate in their application process, particularly for SCS roles.

• Use our data more effectively, including fully implementing the use of our recruitment dashboard to challenge recruitment methodology choices.

• We will also develop a plan to attract a more diverse pool of candidates and build our “Grow Our Own” programmes.

Career progression and development

Ensuring we can provide clear and accessible career progression and development opportunities is key to being able to attract and retain talent. Our 2022 Staff Survey results told us this remains a key area where we can do more to support employees, improving how we raise awareness of opportunities to develop and ensure the programmes we offer are inclusive and offer the widest range of flexible and accessible learning opportunities.

We have already put in place a range of initiatives which we will continue to deliver over the next 2 years.  Examples include:

• We have extended our coaching offer to provide expert support alongside informal workplace mentoring. We have increased our internal pool of coaches, and the visibility of our mentors.

• We offer a number of central cross-government talent and positive action schemes, all aimed at encouraging female staff to achieve their full potential in the Civil Service.

• Following our successful pilot, we have rolled out our mutual mentoring programme, pairing SCS colleagues with mentors from under-represented groups at grades AO to Grade 6. This programme provides development for both partners and builds a greater understanding of the barriers faced by under-represented groups.

Our future plans for 2023 to 2024

Over the next 2 years our Accelerators are:

1. Reviewing our approach to project allocations to ensure access to interesting, varied and challenging work regardless of protected  characteristic or other diverse characteristic.

2. We will also focus on continuing to grow our current programmes, Aspire, Accelerate, Mutual Mentoring.

We also expect to:

• Further develop our coaching offer to include career progression coaching for high potential groups.

• Explore how we can pair colleagues up for a project allocation even where there is no formal job share arrangement in place.

• We will improve managers awareness of flexible working options and how these can work in practice.

Improving representation

We strive for a culture where all our staff are valued, recognised, can contribute, be themselves and thrive.

We welcome and value the unique ideas, skills, behaviours and experiences that our colleagues bring to work because this leads to a more engaged workforce who will make better decisions.

We have already put in place a range of initiatives which we will continue to deliver over the next 2 years. Examples include:

• Our  Aspire development programme now provides a range of skills development courses for all colleagues at grade AO - SEO and Grade 6 – Grade 7. Aspire will be embedded into our core talent offer via the Academy.

• Our Sponsorship programme, Accelerate, is a 12-month programme  providing  focused  development  and  support  to our talented aspiring colleagues from underrepresented groups. It has been designed to provide challenge and support to enable colleagues to progress their careers within the CMA. A lessons learnt exercise will be run to determine how and whether the CMA should run this programme at yearly intervals or less frequently.
• Through our annual cycle of career development and / or succession planning for SCS, ensure women with the aspiration to progress to SCS have the right support in place to prepare them successfully to apply for SCS roles.

Our future plans for 2023 to 2024

Over the next 2 years our Accelerators are:

1. Re-assessing the current CMA talent pipeline to record, track and evaluate individual progress in an even more effective way.

2. Review and improve the application of the temporary promotion policy

3. Implement the CMA’s outreach strategy, including but not limited to offering of internships to ethnic minority groups and women.

Pay and reward

We are committed to ensuring that our future Pay and Reward strategy and approach is transparent, inclusive and supports the CMA ambitions. We fully recognise that as a civil service department it is difficult for us to compete with our external competitors on pay.

With a continued focus on reducing our pay gaps we will ensure that all activities support this drive to address and minimise our gaps.

We have already put in place a range of initiatives which we will continue to deliver over the next 2 years.  Examples include:

• Our pay policies and rules are published on our intranet so that these are available and transparent to all colleagues.

• All CMA campaigns show the minimum and maximum salary that can be offered on appointment and we include wording on adverts to explain how this is applied.

• We ensure that all staff returning from maternity leave, shared parental leave and / or career breaks are not detrimentally affected, and that their pay on return takes into account any pay settlements that have been implemented during their absence.

Our future plans for 2023 to 2024

Over the next 2 years our Accelerators are:

1. Reviewing the effectiveness of both AO to Grade 6 and SCS performance management frameworks, implementing new arrangements by no later than 1 April 2024.

2. Reviewing the CMA’s reward strategy for the distribution of non consolidated pay for AO to Grade 6 and SCS colleagues, with new arrangements in place for the financial year 2024 to 2025.

3. Complete a pay equity audit.

4. Consider adding ethnicity pay gap data to the salary business case process (process currently considers gender pay gap data).

Culture of inclusivity

We are committed to ensuring the CMA’s culture is inclusive, collaborative and respectful.

Each one of these commitments is now encapsulated as 3 of our 6 organisation values.

We have already put in place a range of initiatives which we will continue to deliver over the next two years.  Examples include:

• all new staff complete our induction programme which references culture, respect and inclusion and the Civil Service Expectations elearning module.

• as well as our flexible working policy we offer a range of other policies that support staff to balance their work, home and family life. These include maternity, adoption, paternity, shared parental leave and career breaks.

• we operate a hybrid working model. This will support and engender a culture of trust and provide colleagues with flexibility in how they deliver their work.

• we will continue to support and sponsor our wide range of active staff networks, support our Advisory Committee volunteer participants by providing them with ongoing training and coaching and we will continue to work with key organisations to help us learn and embed good practice.

Our future plans for 2023 to 2024

Over the next 2 years our Accelerators are:

1. We will develop and implement an approach to hold our Executive Committee members accountable for progress on inclusion, representation, pay gaps and the broader measures and actions outlined within this two year plan.

2. We will re-establish all the governance arrangements to monitor, review and ensure delivery of this 2 year action plan.

We also expect to:

• Achieve Career Confident accreditation up and including Level 3