Corporate report

EHRC annual report and accounts 2023 to 2024 (HTML)

Published 12 September 2024

Chairwoman’s Foreword

Having produced, this year, our most comprehensive analysis of Britain’s equality and human rights landscape, we continue to take action to make this a fairer country.

10 December 2023 marked the 75th anniversary of the Universal Declaration of Human Rights. This landmark document set out the fundamental principle that all humans have inherent dignity and equal and inalienable rights. The anniversary was a timely reminder that the rights and protections we enjoy today cannot be taken for granted.

As Britain’s equality watchdog, and an A status National Human Rights Institution, the Equality and Human Rights Commission (EHRC) has a duty to challenge discrimination and protect these rights and freedoms. The breadth and impact of the work we do is demonstrated in this annual report.

The progress Britain has made towards greater equality and respect for human rights – as well as the substantial challenges that remain – was captured by the Equality and Human Rights Monitor report, published in November 2023.

We produce this state of the nation report for Parliament every five years. It is a reference document covering the legal, political and social changes that impact the nine protected characteristics safeguarded by the Equality Act 2010.

The Monitor is intended to support evidence-based debate and decision-making by governments, public bodies and others for years to come. We have urged them all to carefully consider our findings and take forward our recommendations, which focus on the targeted action they can take to help make Britain fairer. We, too, use the evidence base it provides to focus and prioritise our work.

In what was, at times, a challenging year, I am extremely proud of what we continue to achieve. The role of a regulator is not always appreciated, but we have continued to use our powers and resources to make the greatest difference possible to people’s lives, tackling entrenched discrimination or prejudice where we find it. We helped employers understand their responsibility to protect staff experiencing the menopause, and held

a popular holiday park operator to account for their discriminatory practices. We are grateful to those who have helped us to deliver, including members of our Board and Committees, and our staff.

We operate at the forefront of many issues that people care deeply about, and which have come to dominate public discourse in recent years. We act as an impartial and authoritative voice in contentious public debate. We seek to ensure that the sometimes conflicting rights of different groups in society are properly balanced and we encourage respectful public discourse. We thank all of those stakeholders, and the members of the public we serve, with whom we have engaged this year. As our attention turns to 2024– 25, we look forward to continuing to work with all those who can help deliver progress towards our ambition of a society where everyone has equal opportunity to achieve their potential.

The EHRC’s next strategic plan, for 2025 to 2028, will build further towards that ambition, and on the findings and recommendations of the Equality and Human Rights Monitor. I encourage all interested parties to share their views on our future priorities by taking part in the public consultation, which was launched in July.

Baroness Kishwer Falkner, Chairwoman

Chief Executive’s Foreword

Since joining the EHRC it has been a pleasure to meet so many committed and professional colleagues, as well as some of the many stakeholders we frequently engage with. Those conversations have given me a fuller appreciation of the breadth of our responsibilities, the expectations upon us and the constraints we face in delivering on them.

This annual report sets out how we have continued to effectively enforce Britain’s equality laws and champion human rights. We have used our enforcement powers to ensure that organisations from the Home Office to McDonald’s fulfil their obligations under equality law. Last autumn we raised concerns regarding the proposals to close railway ticket offices, which could have had a devastating impact on disabled people and older rail users’ access to travel. The proposal was subsequently withdrawn. And we have submitted evidence to international bodies on compliance with the UK’s human rights treaty obligations in relation to civil and political rights and violence against women and girls.

Our landmark legal support scheme has improved outcomes for victims of alleged race discrimination by helping them access justice that might otherwise have been out of reach. We supported 45 cases. In one of these, we supported an Uber Eats courier who won a settlement following allegations that mandatory facial recognition checks were racially discriminatory. This addressed two of our priorities – achieving equality in a changing workplace and addressing the equality impact of artificial intelligence (AI).

The case is an important reminder that, as the use of AI increases, those who rely on it need to guard against unlawful discrimination. We are already playing a critical and expanding role in the regulation of AI. In June 2023, we advised the UK government on

the safeguards proposed in their White Paper. We continue to work with other regulators to develop and inform our regulatory response to AI. To date our work has focused on specific and identifiable risks to equality and human rights from the deployment of AI technologies.

I am proud of the legislative and policy changes we contribute to by presenting our evidence to parliamentarians and governments across Britain. The Protection from Redundancy (Maternity and Parental Leave) Act, which has just come into force, was inspired by our research. We advised parliamentarians on the equality and human rights implications of potential legislation relating to immigration, criminal justice and digital inclusion. And we have advised the UK, Scottish and Welsh governments, local authorities in all three nations and dozens of public bodies on their obligations under the Public Sector Equality Duty.

Our litigation and policy work has clarified and improved understanding of the law, as have our public interventions in debates and our guidance, for example on managing menopause symptoms at work.

We have prioritised ruthlessly within our limited budget, choosing which of our regulatory interventions to deploy and on what issues to maximise our impact. Our ability to continue to do so depends on our budget keeping pace with inflation. In recent years

it has not. We have had to deprioritise some things we would like to have done. We will continue to press government for a financial settlement that matches our and their ambitions.

We launched our new website this year. This refreshed platform makes the content we publish online significantly more accessible for visitors, which helps them to access the information they need.

Delivering our refreshed website was just one part of the work done over the year to continue to transform the EHRC for the better. The Building our Commission programme is all about ensuring that we have what we need, from strong governance arrangements to analytical skills to leadership development programmes, in place to achieve our

goals together. Our efforts are starting to have impact. Our internal communications arrangements have been improved and staff turnover has declined in the course of the year.

Together our Board, Committees, leadership team and staff are united in our commitment to achieving these improvements. They will put us in the strongest possible position to deliver on our priorities for the year ahead, as well as equipping us to deal with any emerging challenges to equality and human rights.

John Kirkpatrick, Chief Executive

Who we are and what we do

We are Britain’s equality regulator. We were established under the Equality Act 2006 to protect and enforce the laws that ensure fairness, dignity and respect. We are independent of the UK, Scottish and Welsh governments. We are Great Britain’s globally accredited ‘A’ status National Human Rights Institution, with a full human rights mandate in England and Wales and in Scotland in relation to matters reserved to the UK Parliament.

We are experts in equality and human rights. In November 2023, we published the Equality and Human Rights Monitor. This report gives a comprehensive analysis of equality and human rights data across Britain. We make recommendations to governments which use our analysis to shape their policies, and therefore improve the lives of people across the country.

Our job is to challenge discrimination and protect people’s rights across England, Scotland and Wales. We do this by:

1. upholding and explaining the laws that protect people’s rights and freedoms
2. enforcing the Equality Act 2010 in England, Scotland and Wales
3. preventing and challenging discrimination, so that everyone gets a fair chance in life
4. protecting people’s rights, so that everyone is treated fairly, with dignity and respect

Our unique powers enable us to take action when the law is not being followed. We used these powers to investigate Pontins holiday parks when we suspected that they were discriminating against Gypsies and Travellers. Our investigation report was published in February 2024.

The nine protected characteristics in the Equality Act 2010 are:

• age
• race
• sex
• sexual orientation
• pregnancy and maternity
• gender reassignment
• religion or belief
• marriage or civil partnership
• disability

We adhere to the Regulators’ Code, a framework for how regulators should engage with those they regulate, the framework outlines five principles of good regulation. These are:

• proportionality
• accountability
• consistency
• transparency
• targeting

Further information on our approach to regulation and our regulatory objectives is on our website.

Performance report

This performance report summarises what we have achieved in the past year and the context in which we operated in England, Scotland and Wales. It also highlights our work as a national human rights body.

 Introduction

We published our strategic plan in April 2022. As we enter its final year, we continue to work to our six strategic priorities:

• equality in a changing workplace
• equality for children and young people
• upholding rights and equality in health and social care
• addressing the equality and human rights impact of digital services and artificial intelligence
• fostering good relations and respect between groups
• ensuring an effective legal framework to protect equality and human rights

Throughout 2023–24, we focused on our role as a strong equality regulator. We have:

1. enforced the law
2. protected all people’s rights
3. taken action against those who abused the rights of others
4. explained the law clearly, so that everyone can follow it

Our delivery and impact

Equality and Human Rights Monitor

In 2023–24 we published the Equality and Human Rights Monitor. This is our state of the nation report on equality and human rights in Britain. It was published alongside companion reports for Wales and Scotland.

The data in the Monitor gives a mixed picture. Some of what we found is positive. For example, the employment gap between disabled people and non-disabled people has got smaller. The earnings gap has, however, increased. The report also highlights the significant challenges Britain has faced following the COVID-19 pandemic, as well as rising inflation, Brexit and the economic consequences of the war in Ukraine.

We considered a range of stakeholder needs while producing the report, creating different outputs to present information in a variety of ways. We produced an HTML executive summary and downloadable factsheets, as well as the main reports. Stakeholder feedback has been positive. We have received further positive feedback for the beta version of our interactive data dashboard.

We have shared the Monitor with stakeholders to raise awareness of the evidence. In December, we held a Wales Committee launch event in the Senedd for the ‘Is Wales Fairer?’ report. In Scotland, we have been sharing the ‘Is Scotland Fairer?’ report with stakeholders to make them aware of the evidence and our recommendations.

The Equality and Human Rights Monitor will continue to inform how we prioritise and direct our work over the remainder of the current strategic plan. It will also shape the development and delivery of our next plan, for 2025–28.

The sections that follow outline each of our major programmes and their impact over the past year. We also note where we have used our specific powers, and where our work relates to Scotland or Wales.

Equality in a changing workplace

Our goal is to ensure that workers can work free from discrimination, victimisation and harassment. We work towards the elimination of pay and employment gaps for women, ethnic minority and disabled workers and seek to make all workplaces fair and inclusive. We use a wide range of regulatory powers to highlight workplace concerns across sectors, and influenced important new legislation and policy related to the workplace.

Menopause

We recognise that menopause symptoms can have a significant impact on equality in the workplace. We have used our powers to help promote and protect the rights of women at work.

In October 2023, we supported a tribunal hearing on alleged menopause discrimination. Maria Rooney was suffering from menopause symptoms, and anxiety and depression, when she took periods of extended sickness leave from her job as a social worker for Leicester City Council in 2017 and 2018. In February 2022, an Employment Tribunal decided at a preliminary hearing that Ms Rooney was disabled at all material times covered by her claims. This was due to her symptoms of menopause, combined with symptoms of stress and anxiety.

The case involves the first Employment Appeal Tribunal decision that menopause symptoms can amount to a disability for the purposes of the Equality Act. This set a legal precedent.

I am very grateful that the EHRC supported my case and hopefully my case will help other people who may be being discriminated against or harassed in their workplaces.

Ms Rooney

In February 2024, we published new guidance for employers. This is designed to help them understand their legal obligations in relation to supporting workers experiencing menopause symptoms. The guidance made use of research from the Chartered Institute of Personnel and Development and the Fawcett Society. The guidance aligns with our aim to improve and promote equality in the workplace. As of September 2024, the guidance has been viewed approximately 15,500 times on our website.

Sexual harassment

Our Equality and Human Rights Monitor showed that sexual harassment remains prevalent across several areas of life. A UK-wide study conducted by the Government Equalities Office (GEO) in 2020 revealed that 27.0% of men and 30.0% of women experienced sexual harassment in the workplace.

We started work to evaluate the effectiveness of our ‘Preventing Sexual Harassment at Work’ toolkit, designed for the hospitality industry. Building on this evaluation, we published a toolkit to support employers in music sector in August 2024. This has been developed in consultation with organisations from the sector. It helps employers to identify, handle and prevent sexual harassment in the workplace. This precedes the implementation of new sexual harassment legislation in October 2024, the Worker

Protection (Amendment of Equality Act 2010) Act 2023. Our work is intended to ensure that employers have the knowledge, motivation and opportunity to comply with the law, implement positive practice, and proactively protect their workers from harassment.

Following reports of sexual harassment, McDonald’s Restaurants Limited signed a Section 23 agreement with us in February 2023. In July 2023, we set up a dedicated email hotline to help McDonald’s staff report further incidents or concerns around sexual harassment to us. Approximately 275 people have contacted us via the hotline to report concerns about McDonald’s.

We use our power to enter legally binding agreements with organisations. They must commit to not breaching equality law, usually in a specific area where there have been concerns. These are known as ‘section 23’ (s23) agreements, from the Equality Act 2006.

In 2023, we gave funding to support a legal case against Fuller’s Brewery. This involved claims from a former female employee who suffered repeated incidents of sexual harassment from other employees while working as a kitchen assistant and waitress at a Fuller’s pub. The case was settled in June 2023. It included an apology to the claimant for the behaviour she experienced. Fuller’s have now committed to provide

training for thousands of workers within 18 months of the agreement to prevent incidents of sexual harassment.

As well as holding employers to account to improve their workplace practices, we have contributed our evidence base and expertise to inquiries and consultations regarding sex inequality and discrimination.

In September 2023, we responded to the Treasury Select Committee’s inquiry, ‘Sexism in the City’. We analysed recent data regarding pay gaps and the proportions of men and women in senior roles, and used insight from our previous reports to assess progress.

Our work found that the target of 40% of women on the boards of FTSE 350 companies was reached three years ahead of schedule in 2023. However, provisional data from the ONS gender pay gap dataset shows that the 2022 median gender pay gap was disproportionately high, at 36.6% compared to 14.9% across other sectors.

We continue to recommend that the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 are amended. This is the law that requires employers and voluntary organisations with more than 250 employees to publish data on their gender pay gaps. Our recommendation is that these employers and organisations should also be required to implement action plans setting out how they will close their gender pay gaps.

Working across the private and public sector

We aim to proactively prevent equality and human rights issues from arising in the workplace by ensuring employers understand how to comply with the law.

In 2023–2024, we published new guidance for local authorities and public bodies explaining how to ensure that major investment projects have a positive impact on equality of opportunity.

As the regulator of the Equality Act 2010, we are responsible for ensuring compliance with gender pay gap reporting regulations. Where organisations do not comply, we can take action by using our unique powers. In July 2023, we published a list of eight companies who had not reported their gender pay gap by the statutory deadline (31 March 2023). We worked with them to ensure that they submitted their gender pay gap report. In the end, all of them did, and we achieved 100% compliance with the reporting requirements.

We also carried out wider work on pay gaps. In relation to Public Sector Equality Duty reform in Scotland, we responded to the Scottish Government’s consultation on a review of the Scottish-specific duties. We gave advice on compulsory ethnicity and disability pay gap reporting. We continue to advise as the Scottish Government prepares to introduce new legislation.

We gave advice on a number of parliamentary bills related to improving people’s rights at work. These included the Worker Protection (Amendment of Equality Act 2010) Act 2023 and the Protection from Redundancy (Pregnancy and Family Leave) Bill. We also advised the Welsh Government on their response to the Fair Work Wales report.

Equality for children and young people

Many children and young people in Britain encounter discrimination that limits their potential. Our goal is to protect and uphold the rights of all children and young people, including those in institutional care settings who are regarded as especially at risk of not having their rights upheld. This year, we funded important legal cases and worked with governments across Britain to improve educational policies. We reported internationally on the

UK’s compliance with the international Convention on the Rights of the Child.

Advising on education policy to support equality

All young people must have every chance to achieve their full potential. Our work this year aimed to ensure that education settings promote equality for children and young people.

In Wales, we delivered a session on equality impact assessments (EIAs) to officials working on policies and legislation to support the Commission for Tertiary Education and Research. This ensured that equality was at the centre of the Welsh Government’s consultation on subordinate legislation. We also worked with the Welsh Government to embed equality and human rights into the new school curriculum.

Our recommendations to the Welsh Government’s consultation on changes to the school admission appeals code were included in the updated statutory code.

We concluded our Section 23 agreement with the Scottish Qualifications Authority to improve their equality practices. We then used our knowledge from this to inform our response to the Scottish Government’s consultations on an education reform bill.

We submitted evidence to a UK government consultation on the use of reasonable force and restrictive practices in schools. This included raising awareness of our human rights framework for restraint. As a result of our engagement, our recommendations were reflected in the Department for Education’s proposals.

We also responded to the Education Committee’s inquiry into persistent school absence and support for disadvantaged pupils. We set out relevant equality and human rights obligations to help government and schools ensure policies meet diverse needs. Our evidence was referenced in the Committee’s report on persistent absence, which was published in September 2023.

Using our powers under the Equality Act 2010

We supported a case examining the University of Bristol’s failure to make or anticipate reasonable adjustments for Natasha Abrahart, a Physics student who suffered social anxiety. She took her own life in April 2018, shortly before she was due to give a presentation in front of her peers and lecturers. In February 2024, the court ruled that Bristol University had failed to make reasonable adjustments and that Natasha had been discriminated against on the grounds of disability.

Our intervention in this tragic case was welcomed by the judge. It enabled us to challenge discrimination in education, including where there has been a failure to make reasonable adjustments to improve educational outcomes for people with protected characteristics.

In July 2023, we provided funding to support a family whose disabled child had been permanently excluded from school. The family won its appeal against Barlaston Church of England First School. The school excluded the seven-year-old child due to his behaviour

in November 2021. This behaviour was connected to the child’s disabilities: he has ADHD, autism and a sensory processing disorder.

The school apologised to the child and his family, and the inappropriate description of the child’s behaviour was removed from school records. The school also agreed to train its staff on disability discrimination.

In November 2023, we supported a challenge regarding the Legal Aid Agency’s decision not to grant Exceptional Case Funding to a child who was permanently excluded from school. We supported this case to help the child, who is Black and disabled, to receive appropriate legal aid and representation in hearings that challenge discriminatory decisions. At a hearing on 21 November 2023, the claimant was given permission to bring the judicial review, which was heard in May 2024. It is now awaiting judgment.

Human Rights Monitoring

We provided a briefing and oral evidence before the Senedd Inquiry into education access for disabled children and young people. This enabled us to ensure the inquiry was framed within the UN Committee on the Rights of the Child (UNCRC) and Convention on the Rights of Persons with Disabilities (UNCPRD).

Upholding rights and equality in health and social care

Our priorities are ensuring that people with learning disabilities, autism and mental health conditions receive the support they need, improving access to social care, and reducing barriers for people with protected characteristics to receive healthcare. This year, we monitored the recommendations made following our social care inquiry, published in February 2023. We submitted evidence to support important legislative reform, and we used our legal powers to make necessary legal interventions.

Promoting equality and human rights in social care

We continued to monitor and promote the recommendations made in our 2023 social care inquiry. We held webinars with Torfaen Council and Care Inspectorate Wales (CIW) to share ideas and facilitate improvements. We engaged with a range of stakeholders, including the Welsh Government. We wrote to all 22 Welsh local authorities and will follow up on how they have embedded and implemented our recommendations on data collection and varying accessibility formats for social care users.

We published our nine principles for social care in May 2023. This set out how government, social care commissioners, providers and regulators can ensure that equality and human rights are prioritised in social care. We hosted several webinars to share

these principles with organisations and attendees from across the social care sector. We wrote to ministers to share the principles, and to underline how equality and human rights should be embedded into social care policies and practices.

In May 2023, we submitted advice to the government on the development of the Social Care Workforce Pathway. The updated pathway, published by Department of Health and Social Care (DHSC) in January 2024, reflected some of our recommendations on the need for an understanding of equality and human rights law and principles among the workforce.

As part of our Public Sector Equality Duty (PSED) monitoring of local authorities (LAs), we looked at how 97 LAs were considering a range of important equality and human rights issues. This included independent living and the use of AI and digital services to enable home-based care. We followed this up with LAs and ran a seminar with the Local Government Association in September 2023.

We submitted a report to the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) Committee to inform its follow-up review into its inquiry into the rights of disabled people in the UK. We participated in an in-person dialogue with the Committee about our findings. Our report concluded that, while there had been some progress towards implementing legislative and policy measures that respect CRPD rights, more needed to be done to address the rise in inappropriate treatment and detention of disabled people in care settings.

We advised the Scottish Government to ensure equality was embedded in a new National Care Service in Scotland. Several of our recommendations were reflected in the Health, Social Care and Sport Committee’s scrutiny of the legislation. We advised the Scottish Government on how to reflect equality and non-discrimination in the new Charter of Rights and Responsibilities for social care. The charter will be published soon, with an early draft reflecting our recommendations.

We also worked with Integration Joint Boards (IJBs) in Scotland to ensure improvement in compliance with the PSED. We identified that IJBs are important stakeholders in the creation of the National Care Service (NCS), given their remit for planning and commissioning health and social care services. We undertook an improvement intervention to increase PSED compliance, moving the sector from just two out of 30 compliant with key PSED requirements, to all 30 being compliant by end of the year. This ensures that all IJBs now have the knowledge and processes in place to routinely consider equality in their day-to-day operations.

Advice to parliamentarians

In April 2023, we published a parliamentary briefing for an adjournment debate on the abuse of autistic people and people with learning disabilities in in-patient settings.

In August 2023, we responded to DHSC’s consultation on visiting in care homes, hospitals and hospices. We expressed our support for a new Care Quality Commission (CQC) fundamental standard, requiring providers to facilitate visiting.

Engagement with other bodies and organisations

We undertook work with the CQC as part of our commitment to ensuring responsible bodies in the healthcare sector are supported in the promotion of equality and human rights.

As part of our memorandum of understanding with the CQC, we renewed our commitment to sharing information. This included meeting with them to discuss and coordinate action following several high-profile cases where hospitals breached the rights of people in their care. In each case the CQC took strong regulatory action. We also influenced the CQC’s new regulatory framework.

We joined the advisory group for the Rapid Review on Patient Safety. We welcomed the final report’s acknowledgement of the importance of collecting protected characteristic data so that services can better meet the diverse needs of their patients. The report’s recommendations also focused on improving transparency and openness, which will help to address cultures within health and care services that increase the risk of harm. These are known as ‘closed cultures’.

We undertook a focused programme of activities to support the 42 new Integrated Care Boards (ICBs) in England to discuss their obligations under the Public Sector Equality Duty (PSED). We undertook a baseline assessment of how each Integrated Care Board (ICB) is meeting its PSED obligations and provided feedback to almost all of them. We have worked closely with the CQC and National Health Service (NHS) England on this, to maximise our impact. We will look again at ICBs’ compliance over the coming year.

Addressing the equality and human rights impact of digital services and artificial intelligence

Artificial intelligence (AI) poses many challenges to equality and human rights. We are developing our expertise as a regulator of this new and complex technology. We must ensure that the many different ways in which AI can be used do not have a negative impact on everyone’s rights.

We have worked closely with the Department of Science, Innovation and Technology (DSIT) and other regulators as the UK government has developed its approach to regulating AI. In this time, our role has been firmly established through the 2023 white paper, ‘A pro-innovation approach to AI regulation’, and subsequent guidance for regulators, ‘Implementing the UK’s AI Regulatory Principles’. In February 2024, the UK government asked us and 12 other regulators to publish an update on our strategic approach to AI, which we published on 30 April.

Reacting to emerging issues with AI

Our focus is on protecting people’s rights online and regulating providers to ensure ethical standards are robustly maintained. We are monitoring developments to make sure equality and human rights remain a central consideration where AI technologies are deployed.

Throughout 2023, we provided advice and recommendations in response to the Online Safety Bill, which was passed in October 2023. We recommended amendments designed to protect the right to freedom of expression and the right to respect for private and family life, home and correspondence. Our advice was referenced by Parliamentarians numerous times in scrutiny of the Bill, leading to greater emphasis on protecting freedom of expression and assurances from government on privacy protections. We also advised that content moderation features should extend to child users and include all protected characteristics under the Equality Act 2010. Standardised and proactive regulation

online is essential, so we advised the UK government to create a dedicated Online Safety Ombudsman. We also advised Ofcom, the regulator for the communications services, to enhance and standardise its practices to handle emerging risks effectively and fairly.

From May 2023 to March 2024, we produced parliamentary briefings on the Data Protection and Digital Information Bill, drawing on our expertise in the impact of AI to raise concerns and recommend good practice. We noted risks around the increasing use of AI in the collection of data and decision making. We recommended that the UK government retain requirements that effectively safeguard individuals’ rights to data protection and help organisations comply with the Human Rights Act 1998 and the Equality Act 2010, including the PSED.

We continue to monitor emergent issues with AI and proactively use our powers and expertise to protect the rights of the people it affects. Our particular focus is on groups with protected characteristics.

We are a partner in the Fairness Innovation Challenge alongside the Information Commissioner’s Office (ICO) and the Responsible Technology Adoption Unit (RTAU). This initiative has awarded grants to four successful organisations to tackle discrimination in AI in the health, recruitment, higher education and finance sectors.

We delivered our first deep dive into how AI is considered under the PSED. We gathered significant knowledge on how public authorities in England and Scotland are considering equality when commissioning and using AI-based technologies. We used this knowledge to inform our programme of work, including the delivery of a suite of products, which aim to inform and instruct authorities on necessary equality considerations, safeguards and best practice when implementing AI.

Involvement in existing and specific issues with AI

We aim to take proactive and preventative steps to address the risks associated with AI where possible. When there are issues that occur, or breaches of rights are reported, we can intervene and ensure rights are upheld.

We provided funding with the App Drivers & Couriers Union (ADCU) to support Pa Edrissa Manjang’s case against Uber Eats after he experienced continuous difficulties with the platform’s facial recognition technology, which led to his suspension from the app and a deprivation of income. Following our involvement, the case was settled with Mr Manjang.

My case shines a spotlight on the potential problems with the use of AI. I am sure the EHRC will use the learnings and experience of this case to move towards strengthening the rights and protections of workers in relation to AI, particularly ethnic minorities.

Mr Manjang

The ADCU particularly appreciates the support and attention given to this important case by the EHRC as Britain’s equality and human rights regulator.

The App Drivers & Couriers Union

Our preparation for AI and improving access to digital services

We are taking action to ensure individuals’ rights and participation are not impacted by increasingly ‘digital-by-default’ services, particularly those using AI. We aim to help service providers understand and mitigate the associated risks. We continue to deliver against this area of focus but we have not received any additional funding to support it. We could have a greater impact in this complex new area if our funding were increased.

Web accessibility can be a barrier for many groups. Services reliant on technology can carry a high risk of exclusion. Following the Government Digital Service (GDS) monitoring of accessibility in public sector digital services, we have secured compliance with over 70 organisations since the launch of the Meeting the Public Sector Bodies Accessibility Regulations requirements in 2021.

We also identified the use of AI in targeted online advertising as an area of risk. We have scoped a project that has included an internal rapid evidence review, discussions with external stakeholders and other National Human Rights Institutions (NHRIs) and a review of existing, published policies of some social media platforms and job sites. We are now contacting a small sample of social media platforms to understand their approach and compliance with equality standards.

We also undertook a scoping exercise to understand where and how we could have an impact in improving access to non-digital essential public services. We started a

programme of work aimed at improving the understanding and application of the PSED and reasonable adjustment (RA) duty when making decisions to make services digital.

Digital access and AI carry particular risks in the health sector. We started a new two- year programme of monitoring with the 42 new integrated care boards to drive core PSED compliance and action on major health inequalities. We are working on six priority areas:

• tackling racial disproportionality in the use of the Mental Health Act
• moving people with learning disabilities and autistic people out of inappropriate detention settings into their homes
• digital inclusion and the use of AI in health and social care
• race discrimination in NHS employment
• racial disparities in maternity services (and outcomes for women and their babies)
• improving consideration of and action on sexual orientation and gender reassignment

We engaged extensively with stakeholders to develop guidance aimed at small and medium-sized enterprises (SMEs) to improve compliance with the reasonable adjustments duty in hybrid working settings.

How we are helping other bodies prepare for and prevent AI issues

Our preventative approach to tackling issues in AI involves working with public sector organisations and key stakeholders to provide direction around new technology.

We undertook extensive reviews of policies and procedures, as well as stakeholder engagement, to better understand the equality and human rights implications of deploying live Facial Recognition Technology (FRT) in policing. We engaged with:

• the Association of Police and Crime Commissioners (APCC)
• the Mayor’s Office for Policing and Crime (MOPAC)
• Information Commissioner’s Office (ICO)
• His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HIMCFRS)

We also attended live deployments of FRT use to improve our understanding of the technology. We shared our concerns with the National Police Chief’s Council (NPCC) lead for live FRT and subsequently met with the NPCC in February 2024 to discuss further.

Fostering good relations between groups

Fostering good relations between groups with protected characteristics is our obligation under the 2006 Equality Act. We play a leading facilitating role in public debates about equality and human rights issues, including where the balance of rights across different groups must be considered. This year we advised on several important and contentious issues. We published guidance and used our legal powers to challenge discriminatory practice against marginalised groups.

Sex and gender issues

Our role is to clarify the law around sex and gender and ensure that everyone knows what their rights are. We have engaged with a range of different advocacy organisations over the past year and considered views spanning the full breadth of opinion on what is one of the most contested issues in society today.

We are empowered by the Equality Act 2006 and encouraged by the Paris Principles which govern NHRIs to advise the government on issues within our remit. On 3 April 2023, we responded to a letter from the UK Minister for Women and Equalities which asked for our advice on the definition of sex in the Equality Act 2010. We set out our analysis of the legal, policy, and human rights considerations and concluded that on balance, we believe that redefining ‘sex’ in EqA to mean biological sex would create rationalisations, simplifications, clarity and/or reductions in risk for maternity services, providers and users of other services, gay and lesbian associations, sports organisers and employers while risking ambiguity or potential disadvantage in some other areas. We recommended that the UK government move forward on this issue, supported by further analysis and consultation.

Publication of our letter attracted significant, largely positive media comment, and throughout the year we continued to explain and clarify the position with a range of audiences. We met regularly with government department teams leading on sex / gender guidance and updated relationships, sex and health education (RSHE) guidance. We responded to the public consultation on their gender questioning children guidance. We revised our Technical Guidance for Schools in England and Scotland to reflect issues of sex and gender in law and plan to further review and update this guidance in 2024–25.

We engaged with the Cabinet Office, including writing to request assurances that sex / gender guidance was being revised to reflect the balance of rights, protected beliefs, and the law on single-sex spaces.

We worked with bodies such as the Financial Conduct Authority and the Office for Statistics Regulation to improve their understanding of key concepts in the law when collecting data about sex and gender.

We also provided ongoing advice to public bodies regarding sex / gender issues by:

• participating in roundtable discussions between medical regulators regarding requests for same-sex care
• advising the National Police Chief’s Council to remove legally incorrect intimate searches guidance
• writing to the Department for Health and Social Care reiterating our concerns about Gender Identity Clinic waiting times

Pontins investigation

In February 2021, we entered into a legally binding agreement with Pontins after we became aware of the use of an ‘undesirable guest list’ of Irish surnames. Pontins agreed not to commit unlawful acts of race discrimination when providing its services and to take other steps as part of an action plan, including training staff and reviewing its systems and policies. In January 2022, we notified Pontins about potential breaches of the agreement. After considering its response, we ended the agreement and opened a formal investigation regarding the breaches in February 2022 using our unique powers.

In February 2024, we published our investigation report. We found that Pontins committed 11 unlawful acts. Our report also made recommendations, designed to prevent this discrimination from happening again. Pontins was legally obliged to draft an action plan to tackle the unlawful act findings we made. This was based on our recommendations. The implementation of the action plan began on 2 September

2024, with Pontins publishing a formal apology to the Gypsy and Traveller community. We are now monitoring the action plan, which is legally binding. If Pontins does not live up to its commitments, the Equality Act 2010 gives us the power to take further enforcement action.

It is deeply saddening that Irish Traveller people have become so used to hate and prejudice that the Pontins ‘blacklist’ did not come as a surprise.

Whilst we are certain that Pontins are not the only ones operating such discriminatory policies, we welcome the EHRC’s investigation and commend the whistleblower’s principled stance.

Everyone deserves to live free from hate and prejudice.

Chris McDonagh

Campaigns Officer at Friends, Families and Travellers

Engaging with other bodies and organisations

During 2023–24 we continued to deliver against our strategic priorities to promote the value of equality and human rights and respect for others. This includes with educational bodies and across sport. We also prioritised how we can play a leading role in debates about equality and human rights issues. We engaged publicly and with relevant public bodies on significant social issues, such as sex and gender.

Our work in sport

We continued to work with the England and Wales Cricket Board (ECB). Having analysed the recommendations from the Independent Commission for Equity in Cricket’s (ICEC) published report into the state of equity in cricket, we identified 12 recommendations where we believed that, by working with the ECB, we could influence the action plan they were required to produce. We have had several positive meetings with the ECB to discuss their progress on delivering their Equality, Diversity and Inclusion (EDI) action plan and the recommendations of the Independent Commission for Equity in Cricket, particularly those within our remit, including a specific discussion relating to compliance with the Public Sector Equality Duty (PSED).

Ensuring an effective legal framework to protect equality and human rights

The protection of equality and human rights depends on effective legislation. We use our powers, evidence and influence to strengthen the framework that protects equality and human rights in Britain. This year we were ambitious in engaging with a wide range of new legislation with implications for equality and human rights. In May 2024, we launched an investigation and assessment into the Secretary of State for Work and Pensions. We are concerned that equality law may have been broken. Our investigation will continue over the next financial year.

We published guidance on various issues and made significant progress in drafting an updated Services Code of Practice. We also funded cases to tackle race discrimination, building case law and practice in this area through a new legal fund to support individuals experiencing discrimination by race or ethnicity. Finally, we promoted the understanding of, and compliance with, human rights and equalities law. We challenged serious and systemic breaches of the law and used our powers and levers to clarify elements of the law.

Legal cases and agreements

We continued to support cases through our Race Legal Support Scheme. The scheme has run for over 30 months and during this period we have supported 45 cases concerning people who have experienced prejudice and discrimination because of their race. This included two cases in Wales for members of the Gypsy, Roma and Traveller (GRT) community, which settled in their favour.

We supported an Irish Traveller to bring a case against a pub in Cardiff when he was allegedly discriminated against by their refusal to host his daughter’s christening.

Following a claim for direct discrimination on the grounds of his race, the pub agreed to settle with the claimant and has committed to undertake equality and diversity training.

We supported a father and daughter who submitted a claim for race discrimination and harassment against a club who had refused to host their christening party on learning they were Irish Travellers. The father and daughter took legal action against the club on the grounds it had racially discriminated against them both because they were Irish Travellers. The claim also included one of harassment against the father as a result of the staff member’s offensive comments about Travellers. The claimants received compensation and as part of the settlement, three members of staff, a club official and a member of the club board have received cultural awareness training regarding the Gypsy and Irish Traveller communities.

In September 2023, we concluded our legal agreement with the rail provider London North Eastern Railway (LNER), which commenced in July 2020. This regulatory enforcement action followed a legal challenge from a visually impaired customer who received inadequate support and assistance while travelling.

Under the agreement, LNER, which operates trains from London to the north of England and Scotland, were required to improve their assisted travel service and to conduct new training on accessibility and inclusion for all staff who deal with customers. LNER also set up new proactive ways to monitor the assistance it provides and to find new solutions, where needed. The rail operator has also established a disability access forum to generate further improvement initiatives, which have included a new wheelchair space booking feature and a 24-hour booking service for passenger assistance requests.

We supported a student laboratory assistant, Waqas Rai, after he was sacked without notice. He received a financial settlement from his former employer, Micropathology Ltd, following allegations of race and religious discrimination. These were based on an incident following his dismissal when his former manager gave a university lecture, which was recorded and uploaded online. In the recording, the manager could be heard openly discussing the reasons for his dismissal and saying he thought he had been ‘radicalised’. Micropathology Ltd. have published a public statement regarding the case and committed to carrying out equality and diversity training.

I hope that sharing my experience can help prevent it from happening to others in the future, but to anyone who’s been treated like I have, I want to say that there is help out there. I’d like to thank my lawyer and the Equality and Human Rights Commission for their support.

Waqas Rai

We provided legal funding for a case brought by a former soldier who faced discrimination in the British Army due to his beliefs as a practising Muslim. The case was brought against the Ministry of Defence. The claimant spent over eight years as a soldier and faced discrimination, including mockery from other soldiers for wearing his prayer attire and derogatory comments about his Muslim beliefs. He reported his concerns to his chain of command, but they failed to act promptly to address the discrimination. With representation from the Centre for Military Justice, he was able to secure a formal apology and a settlement.

We concluded a legally binding agreement with the Home Office, which was put in place after the Home Office failed to comply with the Public Sector Equality Duty (PSED) when implementing ‘hostile environment’ immigration measures. The improvements, which have now been put in place, included:

• the rollout of training on the PSED for all staff to ensure they are aware of their legal obligations under the Equality Act 2010
• improving the quality of advice to Ministers, to ensure that Ministers due regard to the equalities impacts of policy decisions
• regular identification and recording of equality and PSED compliance risks
• clear ownership of PSED compliance at a senior level

The Home Office has committed to continuing work on meeting the remaining requirements and providing us with a progress update.

Using levers to prevent discrimination

Following a high number of enquiries and concerns raised with the Commission about the closure of ticket offices at railway stations, we submitted a response to the Department for Transport’s (DfT) consultation on the proposed closures. We also undertook a range of reactive PSED interventions, including work with the DfT on their proposed modernisation and requesting their Equality Impact Assessment (EIA) for the proposals. We also worked closely with the Office of Rail and Road on the issue.

We wrote to five Further Education colleges in Wales that appeared to be non-compliant with the PSED requirement to publish a Strategic Equality Plan, equality objectives and equality information. All colleges responded, committing to comply with the PSED following our intervention. We have now achieved 100% compliance for the Further Education sector in Wales.

Sharing knowledge and training others to promote equality

We delivered EIA workshops to Welsh Government officials working on policies and legislation to support the development of the new Commission for Tertiary Education and Research (CTER). This will help to ensure that equality is at the heart of all legislation and policy to support the implementation of CTER. We also delivered EIA workshops to the Children’s Commissioner for Wales team, with polls at the start and end of the sessions showing a considerable increase in confidence from delegates following the workshops.

We also delivered training to over 70 members of the Welsh Government Legal Services Department about our powers and levers.

Human rights monitoring

As the National Human Rights Institute (NHRI) for England and Wales we have a responsibility to promote the effective implementation of the human rights treaties the UK has ratified. Our human rights monitoring work includes providing advice to the UK and Welsh governments and to stakeholders to ensure that human rights breaches are prevented and challenged. We engage with international human rights reviews, including submitting independent reports on implementation of treaty obligations in the UK.

In 2023–24 we advised the government through parliamentary engagement and accompanying media work on new immigration legislation. It threatened compliance with international law and treaty obligations. We also issued public statements on the Safety of Rwanda (Asylum and Immigration) Bill. We consider it to be damaging to the UK’s human rights legal framework and a breach of its obligations under international law.

We published three major reports on the UK government’s compliance with the Convention on the Rights of Persons with Disabilities, the Istanbul Convention and the International Covenant on Civil and Political Rights (ICCPR).

We published our report on how well the UK government has implemented the Istanbul Convention, following its ratification in July 2022. We also developed and ran a webinar explaining the Istanbul Convention monitoring process, with over 70 attendees. Our report was submitted to the Council of Europe Group of Experts on Action against Violence against Women and Domestic Violence (GREVIO) and will inform GREVIO’s baseline evaluation of the UK’s compliance with the Istanbul Convention.

In February 2024 we provided a submission to inform the UN’s examination of the UK’s implementation against the International Covenant on Civil and Political Rights (ICCPR) and engaged in dialogue with the Human Rights Committees as part of the examination in March 2024.

We submitted our response to the Senedd’s Equality and Social Justice Committee inquiry into the Welsh Government’s Draft Child Poverty Strategy. We highlighted the following concerns:

• the strategy had not been sufficiently framed or informed by the CRC
• there was a lack of specific action to address poverty experienced by people with protected characteristics
• the absence of an Equality Impact Assessment for the strategy
• there was a lack of clear and measurable targets and actions

This resulted in changes to the strategy to better incorporate the UN Convention on the Rights of the Child (CRC).

Engagement with other bodies and organisations

We hosted visits from the European Commission on Racism and Intolerance, as well as engaging with special rapporteurs and other experts on our key priorities.

Special rapporteurs are independent experts in human rights. The United Nations (UN) asks them to use their expertise to advise on key human rights issues.

We held roundtable consultations with organisations working on issues related to the human rights of disabled people, women and older people, as well as hundreds of one-to- one stakeholder meetings.

Building our commission

In 2023–24, we continued our internal transformation programme. We refreshed the programme of activity to match the needs and vision of the organisation. We focused on our purpose, our working practices and our knowledge to deliver change which will support development of the EHRC and our people. Overall, we are working to coordinate and drive improvements to ensure that we can achieve the ambition of our strategic plan.

In November 2023 we launched our new website. This was the result of work across many of our teams to review and update content, redesign our content structure and ensure that we have a user-friendly and accessible website.

We have continued to develop our internal decision-making processes, including embedding work undertaken by our regulatory hub. This draws on all sources of information and intelligence about the equality and human rights issues that need our attention. This has enabled us to make quicker decisions, particularly in areas where we need to respond to emerging issues where we can act to promote and protect people’s rights.

Our technology programme delivered further updates to support hybrid working. All of our offices and meeting rooms are now equipped with upgraded video conferencing software. We also upgraded our laptops and personal devices in pursuit of our objective that everyone can access the software and tools they need to do their job.

We continued to deliver on our workplace transformation programme, managing the end of existing leases and working on options for our future office requirements.

Equality Objectives

In line with our own Public Sector Equality Duty obligations, we have three equality objectives which guide our work:

Equality objective 1: We will promote equality and tackle discrimination by achieving the priorities set out in our strategic plan.

Our priorities are described in our strategic plan and are aimed at creating a society that is fair and where people live well together. Our annual business plan is developed to deliver our priority areas of focus. The performance section of this report identifies what we have achieved in the second year of delivery against our strategic plan.

Equality objective 2: We will seek to address under-representation of people with different protected characteristics in EHRC, including at senior levels.

Our second equality objective relates to our corporate improvement and our people. Our recruitment processes are designed to ensure that all candidates are appointed on merit. Our analysis indicates that we continue to have a diverse staff workforce. We also have a diverse Board and statutory committee membership. Achieving a diverse workforce at every level, including at the most senior staff levels, remains a priority goal.

Equality objective 3: We will make sure our evidence is robust, impartial and enables understanding of the different needs and experiences of protected characteristic groups.

Our third equality objective focuses on the evidence we use to achieve our strategic priorities and on encouraging others to collect and use data to make evidence-based decisions to protect and promote equality for all. In 2023–24 we used the intelligence generated by our Regulatory Hub to improve the way we use evidence to make decisions about where we deploy our regulatory levers.

We delivered our latest Equality and Human Rights Monitor and associated reports for Scotland and Wales, alongside a series of factsheets which show whether progress is being made towards achieving greater equality across Britain.

Our Business

As Great Britain’s equality regulator, we regularly engage with stakeholders and governments across England, Scotland and Wales. With a head office in Manchester, we have additional offices in London, Cardiff and Glasgow and we have access to a small number of touchdown desks in Edinburgh. Our workforce is organised into two functional areas, our regulatory network and our operations network, each led by a senior officer.

Staff are spread across all offices, with conferencing facilities available, and can meet and collaborate from any office or individually. We also have a small number of staff who are employed on an ‘at home’ basis.

Financial Performance

Our 2023–24 delegation letter confirmed our resource budget of £17.1 million (excluding depreciation). This represented a flat cash settlement in line with previous years and a further real-terms reduction giving rise to significant budget pressures during 2023–24. We took steps to mitigate the impact of these pressures and held regular review meetings with the Cabinet Office. Additional budgetary cover to the extent of £0.8 million for new pressures was agreed as part of supplementary estimates in February 2024. This resulted in a revised budget of £17.9 million.

The initial £17.1 million was allocated as £12 million administration and £5.1 million programme funding, with the additional £0.8 million apportioned between administration and programme funding in line with spending. Our total net operational resource expenditure at 31 March 2024 was £17.7 million, an underspend of £0.2 million (1.2%) compared to the revised budget.

Capital project funding provided was £0.5 million, and our investment in year was £0.244 million, an underspend of £0.256 million.

Further information is provided in the statement of accounts and notes to the accounts for the year to 31 March 2024 which are set out from page 125 onwards.

Total budget

The table below summarises total expenditure against budget (excluding capital and depreciation)

Year ended	Total budget £000	Additional funding provided £000	Total funding envelope £000	Total spend £000	Variance £000
31 March 2024	17,100	800	17,900	17,692	208

We used our budget allocation to achieve our business plan objectives, delivering both planned and reactive work as outlined in the Performance Report.

Our business planning and finance teams worked with budget holders during the year, holding monthly review meetings to monitor activity and spend against milestones contained in project plans. We continued to develop our agile approach to business planning, which has enabled us to re-prioritise and reallocate budget to areas that would have most impact.

The chart in the expenditure summary 2023–24 section provides a breakdown by expenditure headings.

Expenditure summary 2023–24

In 2023–24 we spent a total of £17.692 million compared to £17.636 million in 2022–23. Our largest area of spend is staff costs which amount to 82.5% of total spend. A high proportion of our work involves enforcing the Equality Act and providing advice, evidence and guidance for the public. This work is mainly delivered by internal staff and, where required, it is supported by procuring external goods and services.

Spend 2023–24 (£000)

• Corporate costs: 2,460
• External spend: 544
• Staff, Board and Committe costs: 14,688

The table below provides a comparison with our 2022–23 spend

Category	2023–24 £000	2022–23 £000	Change £000
Staff, Board and Committee costs	14,688	14,156	532
Corporate Costs	2,460	2,805	(345)
External Spend	544	675	(131)
Total	17,692	17,636	56

During 2023–24 staff turnover has continued to reduce. We have invested in additional staff with the specialist skills and expertise we need to deliver our work while also seeking to reduce our overall staff profile, to remain within budget. This was achieved through targeted vacancy management. Staff costs represented 82.5% of total spend (2022–23, 80.3%) and have increased due to salary increases and due to more staff being in post for the full year. We have also reduced our reliance on temporary (agency) staff during the year with spend in this area reducing from £373,000 in 2022–23 to £43,000 in 2023–24.

Corporate costs are those associated with running the organisation, including IT systems, premises, recruitment, learning and development and financial services. While corporate costs tend to be regular and fixed, in-year savings have been achieved through contract reviews. We have also continued to invest in our infrastructure and estates to facilitate remote and hybrid working.

Expenditure on external delivery costs reduced during 2023–24 as a result of more work being delivered by internal staff. The majority of external expenditure was on the continued support of legal cases through the Race Legal Support Fund and on developing our publication and media profile.

During 2023–24 we spent £0.244 million of our total capital budget of £0.5 million. Spend included completion of the fitout of our Cardiff office. Changes to relocation plans in Glasgow were the most significant reason for the underspend against the £0.5 million budget. We completed the renewal of video conferencing equipment, enhancing capacity and compatibility with other systems, and completed a refresh of user devices to enhance remote working. These investments will help to reduce our environmental impact, as detailed from page 54 in our sustainability report.

Capital structure

Our capital structure is shown as taxpayers’ equity in our financial statements. Expenditure is funded by grant-in-aid received from the Cabinet Office as our sponsoring department. We monitor our cash flow and our financial forecast to ensure we have sufficient cash to meet our net liabilities and to pay our creditors promptly. We ended the year with a cash balance of £244,000 (2022–23: £32,000). The statements of financial position and changes in taxpayers’ equity in the statement of accounts provide more information.

Long-term expenditure trends and value for money

Resource funding for 2023–24 was used to fund staffing costs, overheads and our programme of work. In line with other public bodies, the EHRC is subject to government spending controls. Our baseline budget has remained at £17.1 million, with no additional uplift to account for inflationary costs. Due to unavoidable pressures, additional and one- off funding of £0.8 million was provided by the Cabinet Office through the supplementary estimates process.

In 2012, a financial review of the EHRC concluded that we required a budget of £17.1 million in 2012–13 to carry out our basic statutory functions. Taking inflation into account, using the Bank of England inflation calculator, this would now be £23.7 million. As such, our current baseline budget of £17.1 million represents a real-terms reduction of over 38%. In 2023–24 we worked to reduce our overall expenditure by filling vacancies on a case-by-case basis and further reducing our external expenditure by delivering more in- house, where possible to absorb inflationary pressures.

This continued real-terms pressure on our budget means that we are making difficult prioritisation decisions for our delivery. We must carefully balance our responses to fast moving areas of focus, such as artificial intelligence, against our core duties and responsibilities. We have also been required to make decisions about how to allocate our limited resources in responding to emerging issues, all while ensuring that we remain within our baseline budget.

Long-term expenditure trends (£000)

Year	Purchase of goods and services	Staff and Commissioner costs	Income
2023-24	3,032	14,688	-28
2022-23	3,606	14,156	-126
2021-22	4,508	12,199	-145
2020-21	4,040	12,866	-168
2019-20	5,253	12,111	-305
2018-19	6,182	11,837	-289
2017-18	7,597	10,635	-121

Payment of suppliers

We follow the government’s prompt payment guidance to ensure that suppliers are paid quickly. 88% of all invoices received were settled within five working days and 99.7% of undisputed invoices were paid within the target of 30 days.

Further information is available on our website.

Our people

During 2023–24, employee turnover remained consistently below the previous year. Our rolling annual turnover of permanent staff was 13.8% on 31 March 2024, a reduction from 16.5% on 31 March 2023.

We continue to review and improve our processes for offering confidential exit interviews to fully understand reasons for leaving. From April 2024, we have been trialling outsourcing our exit interviews to an external partner, to improve both participation and the quality of feedback on our working environment, culture, and relationships.

We have taken active steps throughout the year to ensure that our workforce remains affordable. On 31 March 2024, we employed 216 people, with a full time equivalent of

203.68. Compared with 31 March 2023, this is a reduction of 12.3 FTE. We continue to review and adapt our structures and ways of working to ensure they remain aligned with organisational strategy and needs.

Our baseline sickness absence rate increased, with an average 7.9 working days lost (AWDL) per employee in 2023–24, compared with 6 days in 2022–23. Increases are due to winter viruses and a small number of long-term absences which have a disproportionate impact in a small organisation. We have a programme to reduce

sickness absence, including coaching and support for managers, reviewing and improving our absence management policy and procedures and providing regular report to senior managers.

Our pay gaps

Pay gaps measure the difference in gross hourly earnings between two groups, based on gross salaries paid directly to employees.

• the gender pay gap measures the difference between male and female sexes
• the ethnicity pay gap measures the difference between white British and ethnic minority employees
• the disability pay gap measures the difference between employees who declare a disability and those who do not

The median pay gap is the difference between the midpoints in the ranges of hourly earnings. It takes all salaries in the sample, lines them up in order from lowest to highest, and picks the middle salary. This is the more representative measure of the pay gap because it is not affected by the few individuals who are outliers at the top and bottom of the range.

The mean pay gap is the difference between the average hourly earnings.

Our pay gaps are measured as at the last financial year (2022–23) in line with Civil Service reporting standards. As shown in the table below, on 31 March 2023, we saw further reductions in all mean pay gaps, with a small increase in the median calculations.

Snapshot date	31 March 2023 - Median %	31 March 2022 - Median %	31 March 2023 - Mean %	31 March 2022 - Mean %
Gender pay gap	3.5	0.0	2.8	6.4
Ethnicity pay gap	4.1	0.3	0.4	7.8
Disability pay gap	4.1	0.0	9.7	12.3

All of our mean pay gaps have reduced from 2021–22 figures and the distribution of sex, ethnicity, and disability across pay quartiles continues to be more balanced, demonstrating overall improvements in equality. Other factors, such as bonus payments, allowances, and positive shifts in the distribution of these groups across the pay quartiles have widened the median pay gap.

Factors that affected our pay gaps in 2022–23 include:

• the inclusion of a bonus payment in the snapshot month (March 2023) led to differences in the gross hourly earnings of female and male colleagues, and in ethnic minority colleagues and those declaring an ethnicity of White British
• a higher proportion of females joined the EHRC in year, leading to a greater number receiving a pro-rata bonus payment than males
• an increase in females holding senior positions within our organisation has contributed to the narrowing of our mean gender pay gap

Detailed explanations for these changes for each group will be provided in our Pay Gap report.

Workforce Diversity

Our inclusive recruitment practices enabled us to maintain a diverse workforce. Changes in our workforce diversity are outlined in the following table.

Characteristic	31 March 2024	31 March 2023	Difference
Ethnicity	-	-	-
Ethnic minority	23%	23%	–
White British	73%	72%	+1%
Prefer not to say/not declared	4%	5%	-1%
Sex	-	-	-
Female	64%	64%	–
Male	36%	36%	–
Prefer not to say/not declared	–	–	–
Marital status	-	-	-
Married or in a civil partnership	42%	42%	–
Not married or in a civil partnership	43%	42%	+1%
Prefer not to say/not declared	15%	16%	-1%
Religion or belief	-	-	-
Religion or belief	30%	29%	+1%
No religion or belief	59%	59%	–
Prefer not to say/not declared	11%	12%	-1%
Disability	-	-	-
No	73%	72%	+1%
Yes	19%	18%	+1%
Prefer not to say/not declared	8%	9%	-1%
Sexual orientation	-	-	-
Lesbian, gay, bisexual, other	11%	12%	-1%
Heterosexual/straight	76%	73%	+3%
Prefer not to say/not declared	13%	15%	-2%
Caring responsibilities	-	-	-
No	51%	50%	+1%
Yes	43%	41%	+2%
Prefer not to say/not declared	6%	9%	-3%
Age	-	-	-
16–24	*	2%	–
25–34	28%	28%	–
35–44	29%	28%	+1%
45–54	25%	25%	–
55+	18%	17%	+1%
Gender reassignment	-	-	-
No	91%	87%	+4%
Yes	*	3%	–
Prefer not to say/not declared	*	10%	–

(*) information about groups of fewer than five is not published to protect anonymity.

Communications

In 2023–24, we continued to maximise our impact and share our work with the public and stakeholders. We maintained the increase in media coverage seen in 2022–23 and continued to navigate through highly contested areas of work. As can be seen in the ‘average media sentiment graph’ below, our positive media sentiment has further improved.

Average media sentiment

• Neutral: 33.80%
• Negative: 4.60%
• Positive: 61.60%

In 2023–24 average media sentiment was 61.6% positive (2022–23 51%), 33.8% neutral and 4.6% negative (2022–23 6%) This means for 2023–24 we have seen over a 10% increase in positive media sentiment and over a 1% drop in negative media coverage.

Year	Total media mentions
2021-22	1,358
2022-23	2,467
2023-24	2,217

The chart above shows that our total media mentions were slightly fewer than in 2022–23 but still represent a significant increase on mentions in 2021–22 and reflect our improved strategy and approach to this area of our work. We launched our new website and we strengthened our stakeholder engagement and content teams to help maximise our reach. This is further shown in the average engagement with the stakeholder newsletter and the year-on-year increase in social media followers.

Average stakeholder newsletter engagement

Year	2021-22	2022-23	2023-24
Average open-rate	33%	37%	46%
Average click-through rate	16%	12%	16%

Year	Social media followers
2021-22	94,016
2022-23	101,992
2023-24	111,272

Year	2021-22	2022-23	2023-24
Internal newsletter engagement rate	42%	77%	91%

Internally, we made further changes to professionalise our approach to staff engagement. We delivered monthly all staff online updates, with strong attendance from staff and senior management. Our internal newsletter has maintained a high engagement rate with 91% open-rate.

Sustainability reporting

We are committed to creating a sustainable workplace and protecting the environment with the resources available to us.

The Greening Government Commitments (GGC) set out the actions government departments and their agencies must take to reduce their impacts on the environment. The current framework runs until 2025, with a view to achieving net-zero carbon emissions by 2050. EHRC recognises that taking action related to sustainability is a key priority for colleagues at every level and contributed towards ensuring that the government meets its net zero objectives.

As a non-departmental public body of fewer than 250 employees, we were previously exempt from the mandatory sustainability and environmental reporting requirements. Our data from 2022–23 is our baseline for comparison in this year’s reporting and future years.

We recognise that carbon offsetting may become a feature of future net-zero planning, but for now we are focused on achieving reductions.

In addition to our reporting obligations, we are committed to maintaining ethical and sustainable business practices, which consider the social, economic and environmental impact of our work. In 2023–24, we continued to take practical action to review and improve our processes to embed consideration for the environment into all relevant decision making. We also took steps to improve our internal capability and understanding of sustainability and carbon literacy, supported by an employee-led sustainability network.

Our work in 2023–24 included:

• Growing our sustainability network to 25 members of staff, representing all four office locations. The network meets monthly and has published regular internal blogs covering different aspects of environmental consciousness, encouraging colleagues to adopt greener practices in various aspects of their lives including participating in the World Wildlife Fund’s Earth Hour in support of global environmental awareness.
• Continuing to encourage recycling in our offices, we have introduced battery recycling bins, enabling the recovery of metals and other materials. This reduces the impact on the environment caused by sending these to landfill.
• Contracting a new cleaning provider for our Manchester office. The successful company showed commitment to promoting the principles of sustainability in their response and scored highly in this area. They have committed to achieving Net Zero emissions by 2040 and predict a 30% carbon emissions reduction by 2027. They do not use any single use plastics and use PVA biodegradable water-soluble cleaning sachets.
• Helping to shape HR policies by participating in the HR Policy Hub. We influenced the menopause policy including the provision of feminine hygiene products in each of our offices, which are provided by a supplier holding several certifications including ICEA (Ethical and Environmental Certification Institute), Climate Neutral and Certified Organic Cotton.
• Ordering stationery items that are 100% recyclable or made from sustainable materials, ensuring environmentally responsible purchases.

Scope and data

Our offices are based in shared buildings where we are a minor tenant and are not the decision maker regarding most areas covered by GGC. Separate meters are not in place for sub-tenants therefore utilities and other services are recharged to us by based on the percentage of the floor area of the building we occupy rather than on actual consumption, the metrics reported are extrapolated from our percentage occupancy of the property by the landlord.

In Companies House, Cardiff and, until recently, Bothwell Street, Glasgow 80% or more of the property was occupied by one tenant (Companies House and Student Loans Company, respectively). Therefore, as the major occupier, they will report for the whole building.

We have only included data from our London office (Windsor House – ‘WH’) and Manchester office (Arndale House – ‘AH’) in this report where the information is available.

The following reporting areas are not applicable:

• Nature recovery and biodiversity action planning – the EHRC does not have any landholdings or natural capital. To compensate for the lack of opportunity to develop an action plan, we are exploring volunteering opportunities, including litter picking.
• Travel car fleet – the EHRC does not own, lease or hire any car fleets.

The tables on the next page report on our position at 31 March 2024.

Mitigating climate change: working towards net-zero by 2050

GGC target:

Reduce overall emissions by 52% and reduce direct emissions by 20% from the 2017–18 baseline by 2024–25, with a view to net-zero by 2050.

Tonnes of carbon dioxide equivalent (CO2e)

Greenhouse gas (GHG) emissions	2023–24	2022–23
Scope 1 (direct) emissions	12.51	10.99
Scope 2 (energy indirect) emissions	13.62	16.82
Scope 3 (official business travel – domestic) emissions	15.52	5.27
Total greenhouse gas emissions	41.65	33.08

Kilowatt hours (kWh)

Greenhouse gas (GHG) emissions	2023–24	2022–23
Energy electricity green tariff (scope 2 and 3)	–	–
Mains standard grid electricity consumption (scope 2 and 3)	87,212	87,000
Natural gas	67,835	60,220
District heating systems	–	–
Heat from other sources	–	–
Total related energy use	155,047	147,220

£

Greenhouse gas (GHG) emissions	2023–24	2022–23
Expenditure on energy	9,747	9,090*
Expenditure on official business travel	193,220	148,298
Total related expenditure	202,967	157,388

(*) Figures shown indicate which office they relate to. Most are for our Arndale House office in Manchester. Figures for some of our other offices have either not been made available by the Government Property Agency (GPA) or are consolidated in an overall service charge from the GPA and are therefore not shown.

The table above includes data relating to our Windsor House (London) and Arndale House (Manchester) buildings. During 2023–24, we left our Bothwell street (Glasgow) office when the lease expired. Due to the EHRC not entering into a new lease immediately,

the total carbon footprint saving to 31 March 2024 was 360 CO2e. We anticipate that we will improve on the target in future years as we move to new offices in Glasgow and London. Expenditure on business travel is increasing, but we are encouraging our teams to make greener choices where possible, and our provider includes information about sustainability when booking.

Domestic and international flights

GGC target:

Report the distance travelled by international business flights, with a view to better understanding and reducing related emissions where possible.

The Cabinet Office has set ambitious internal targets to reduce domestic flight emissions by 50% by 2050.

In 2023–24, we travelled 17,057 miles (27,445 kilometres) by domestic flights, releasing 7.178 tonnes CO2e (with RF) emissions. The main reasons for domestic travel are face to face meetings in our offices (for staff and Board members).

In 2022–23, we travelled 17,815 miles (28,670 kilometres) by domestic flights, releasing 7.049 tonnes CO2e (with RF) emissions.

We encourage all staff to always take the lower carbon travel option where possible, with our central booking system making the climate impact of travel clear to the user. We have invested in technologies that enable hybrid working between teams from multiple locations.

In 2023–24, the distance travelled by international flights was 25,496 kilometres, releasing 4.661 tonnes CO2e (with RF) emissions.

This includes staff travelling for conference attendance in Europe (Geneva / UN).

This is a reduction compared to 2022–23, where the distance travelled by international flights was 28,670 kilometres. We are reviewing our travel and subsistence policy and considering how we can better highlight more sustainable options for travel.

Minimising waste and promoting resource efficiency

GGC target:

Reduce the overall amount of waste generated by 15% from the 2017–18 baseline.

We remain committed to our reuse rather than recycle principles, and are looking

at supporting furniture and digital poverty schemes by donating surplus equipment.

The EHRC is unable to report on waste at Arndale House. However we continue to work with the landlord to improve monitoring and reporting for our proportion. While our waste generated has increased, we are also increasing the amount that we recycle by a similar proportion.

Tonnes	2023-24	2022-23
Total waste reused or recycled externally (excluding ICT waste)	0.624	0.369
Total waste to landfill	0.828	0.335*
Total ICT waste: recycled (externally)	–	–
Total ICT waste: reused (externally)	–	–
Total waste incinerated with energy recovery	–
Total waste incinerated without energy recovery	–	–
Total waste composted or sent to anaerobic digestion	–	–
Total waste recycled	0.624	0.369
Total waste	1.452	0.704
£000’s Total waste disposal cost**	Not available	Not available

(*) Total waste to landfill for 2022–23 was incorrectly reported as total waste incinerated in the 2022–23 report and has been corrected in the table above.

(**) Waste disposal costs are contained within contracts covering service charges and office cleaning and are not separately identifiable.

Paper consumption

GGC target:

Reduce government’s paper use by at least 50% from a 2017–18 baseline.

In 2023–24, we procured 23.4 boxes of A4 paper (117 reams), compared to five reams in 2023–23 and zero reams in 2021–22. We purchase only recycled paper, which we also recycle after use wherever possible.

In 2023–24, our printers consumed the equivalent of 38,810 sheets of A4 paper in total across all sites, which resulted in an estimated 493kg of CO2 produced. For 2023–24 we have changed the way we analyse this data due to a change in printing software. The new software calculates the kg CO2 differently and paper consumption is based on sheets of paper used instead of individual pages printed.

Our consumption for 2023–24 indicates a significant decrease in kg CO2 from 2022–23, where we printed 74,027 pages in total across all sites (which resulted in an estimated 562kg of CO2 produced).

We record paper savings from print jobs that were sent to our printers but not released within 72 hours. In 2023–24, we saved 9,123 sheets (116kg CO2 saved, based on the new software calculation).

EHRC only came into scope for this target in 2022, which means that our baseline (2022–23) is disproportionate due to the impact of the pandemic on office usage in that timeframe. We will consider 2023–24 as our baseline from which to reduce and we intend to do this by 2025, in line with the target period.

Category	2023–24	2022–23
Reams of paper procured (A4 equivalent)	117	5
Cost of paper (£)	365.81	17.97
Printed output	38,810 (sheets) (493kg CO2)	74,027 (sheets) (562kg CO2)
Savings from print jobs not released	9,123 (sheets) (116kg CO2)	11,359 (sheets) (80kg CO2)

Reducing our water waste

GGC target:

Reduce water usage by 8% against the 2017–18 baseline.

Costs for utilities form part of a total service charge from our landlords and are not identified separately. Improvements in monitoring and measurement of water consumption are in hand.

Based on the figures provided by our landlords, our water consumption has reduced by 152m3; 29 per cent compared to 2022–23.

Category	2023–24	2022–23
Water consumption - Cubic metres (m³)	366	518
Total water cost - £000	Not available	Not available

Procuring sustainable products and services

The EHRC works in alignment with the Greening Government Commitments. We are committed to sustainability in the way goods are procured and we work with our suppliers to understand and reduce the impacts of their supply chains.

This includes:

• embedding the UK government’s overarching priorities of value for money and streamlining procurement processes
• adhering to reporting requirements by publishing data on environmental impact
• evaluation criteria to include social and economic factors in addition to environmental factors where applicable
• using Crown Commercial Service frameworks to offer solutions that comply with all relevant standards and include sustainability factors as a criterion for award
• enabling the delivery of social value in public sector contracts through effective contract levers
• helping address the risks of modern day slavery in supply chains
• supporting small and medium-sized enterprises through our procurements

Reducing environmental impacts from ICT and digital

We operate a fully sustainable portfolio of ICT services. Where new opportunities arise, we consider from the outset the whole life environmental and landfill impacts. Good progress has been made through:

• Expanding our use of cloud services and reducing the need for legacy physical infrastructure in 2023–24. Where we have a requirement for new physical IT infrastructure we have ensured that new equipment is sized according to our needs. Our cloud partner aims to use 100% renewable energy by 2025.
• Embedding our new video conferencing equipment and underlying technology which has been rolled out to all locations to strengthen hybrid working and to facilitate meetings between teams based in various locations across the UK. This reduces the need for both staff and external stakeholders to travel to meetings.
• Completing the refresh of all laptop devices with better energy efficiency through modern design, improvements to battery life and optimised power saving profile.

Going Concern

Our financial statements have been prepared on a going-concern basis. This is based on our assessment that we will continue to receive funding and our operations will continue for the foreseeable future.

This assessment has also considered that, for non-trading public sector entities such as the EHRC, the government financial reporting manual (FReM) provides that ‘the anticipated continuation of the provision of a service in the future, as evidenced by inclusion of financial provision for that service in published documents, is normally sufficient evidence of going concern’.

The Equality Act 2006 requires the Secretary of State to provide sufficient funding for us to carry out our statutory functions and we are financed through grant-in-aid from our sponsoring department, the Cabinet Office. Our 2024–25 budget and grant-in-aid funding is included in the Cabinet Office main estimates for the year, and we have been issued our budget delegation for 2024–25.

John Kirkpatrick

Chief Executive and Accounting Officer

10 September 2024

Accountability report

The accountability report includes the corporate governance report, the remuneration and staff report and the parliamentary and audit report.

These sections reflect the financial and parliamentary accountability reporting requirements.

Corporate governance report

The corporate governance report explains how our governance, risk management, internal control arrangements and management structures support the delivery of the annual business plan, how we measure progress against the strategic plan and provide assurance of the effectiveness of our internal controls.

The Board of Commissioners, chaired by the Chairwoman, determines corporate strategy and policy and oversees corporate performance. It receives advice and assurance from its Audit and Risk Assurance Committee and its People and Workspace Committee. The Board is also advised by its statutory Scotland and Wales Committees.

The Leadership Team, chaired by the Chief Executive, is responsible for operational decisions, for delivering to the objectives set by the Board, and for all aspects of performance and business improvement.

Board of Commissioners

The Board of Commissioners is our most senior decision-making body. The Board’s responsibilities include setting the strategic direction, reviewing overall performance and delivery, and ensuring good governance. It delegates management of operations to the Chief Executive and staff to account by monitoring performance against priorities and making sure that resources are used effectively and efficiently.

The Chairwoman is responsible for setting the Board’s agenda and for ensuring that meetings are conducted properly, promoting openness in debates to ensure that items are adequately discussed and that decisions are made.

The UK government’s Minister for Women and Equalities appoints our Chair and Commissioners. Profiles of our current Commissioners are on our website and details of their terms of office are in the remuneration report on page 90.

On 31 March 2024, the Board comprised nine non-executive members. The Chief Executive is a Commissioner ex officio. The recruitment process for additional Commissioners was underway and was paused by the announcement of the 2024 General Election.

There were seven routine and four additional Board meetings during 2023–24.

Attendance at meetings is shown below. Board meetings cover all aspects of our work on regulation, policy, strategy and corporate services as well as emerging equality and human rights issues. The Board received regular updates from its Committees to gain further assurance and strategic advice.

Board meetings attendance by Commissioner and Chief Executive

Name	Attendance / eligibility
Baroness Kishwer Falkner (Chairwoman)[footnote 1]	10/10
Eryl Besse (Deputy Chair until 27 September 2023)	4/5
Alasdair Henderson (Deputy Chair until 27 September 2023)	9/10
Dr Lesley Sawers (Interim Deputy Chair from 28 September 2023)	11/11
Arif Ahmed	2/2
Jessica Butcher	11/11
Joanne Cash	11/11
David Goodhart	11/11
Kunle Olulode	11/11
Akua Reindorf	11/11
Su-Mei Thompson	6/6
Martyn Jones[footnote 2]	3/4
Marcial Boo (Chief Executive until 31 December 2023)	3/4
Cath Denholm (Acting Chief Executive from 17 September 2023 to 31 March 2024)	6/6

Committees of the Board

The board receives support and advice from four Committees. Details of these are below.

Scotland Committee

The Scotland Committee uses its statutory powers in the Equality Act 2006 to advise the Board on the impact of work in Scotland and advise new laws or proposed changes to the law that affect only Scotland.

The Scotland Committee held three formal meetings during 2023–24 and is chaired by the Scotland Commissioner, Dr Lesley Sawers.

In 2023–24, the Scotland Committee gave advice to the Board on matters that impact in Scotland, including: the 2025–28 Strategic Plan, the 2024–25 Business Plan, the Scottish Government Human Rights Bill consultation, City Region Deals, Scottish public sector duties reform, and the Scottish Government Banning Conversion Practices consultation.

The Scotland Commissioner held meetings with stakeholders, including: the Scottish Labour Party Leader, the Scottish Cabinet Secretary for Wellbeing, Economy, Fair Work and Energy, the Scottish Minister for Equalities, Migration and Refugees, and the Scottish Cabinet Secretary for Justice of Scotland.

More information about the Scotland Committee and its work is on our website

Scotland Committee formal meeting attendance

Name	Attendance / eligibility
Scotland Commissioner, Dr Lesley Sawers (Chair)	3/3
Rami Okasha (term ended on 3 January 2024)	2/2
Mariam Ahmed	3/3
Tatora Mukushi (resigned on 11 August 2023)	0/0
Lindsey Millen (resigned on 8 June 2023)	0/0
Adam Tomkins	2/2
Lesley Thomson	2/2
Arlene Stokes	2/2
Mandy Rhodes	1/2

Wales Committee

The Wales Committee uses its statutory powers in the Equality Act 2006 to advise the Board on the impact of work in Wales and give advice about new laws or proposed changes to the law that affect only Wales.

The Wales Committee held five formal meetings during 2023–24. The Wales Commissioner, Eryl Besse resigned on 31 October 2023. Martyn Jones, Wales Committee Member, chaired the Wales Committee from 2 November 2023.

In 2023–24, the Wales Committee gave advice to the Board on matters that impact equality and human rights in Wales, including: development of the 2025–28 strategic plan; development of the 2024–25 business plan; strengthening and advancing equality and human rights in Wales; and diversity in public appointments. The Committee also undertook an effectiveness review.

The Wales Commissioner was regularly in contact with Welsh Government Ministers, including the Minister for Equalities and Social Justice. Meetings also took place with The Older Peoples Commissioner, The Children’s Commissioner and The Future Generations Commissioner, as well as a range of other senior stakeholders.

Scotland Committee formal meeting attendance

Name	Attendance / eligibility
Scotland Commissioner, Dr Lesley Sawers (Chair)	3/3
Rami Okasha (term ended on 3 January 2024)	2/2
Mariam Ahmed	3/3
Tatora Mukushi (resigned on 11 August 2023)	0/0
Lindsey Millen (resigned on 8 June 2023)	0/0
Adam Tomkins	2/2
Lesley Thomson	2/2
Arlene Stokes	2/2
Mandy Rhodes	1/2

Wales Committee

The Wales Committee uses its statutory powers in the Equality Act 2006 to advise the Board on the impact of work in Wales and give advice about new laws or proposed changes to the law that affect only Wales.

The Wales Committee held five formal meetings during 2023–24. The Wales Commissioner, Eryl Besse resigned on 31 October 2023. Martyn Jones, Wales Committee Member, chaired the Wales Committee from 2 November 2023.

In 2023–24, the Wales Committee gave advice to the Board on matters that impact equality and human rights in Wales, including: development of the 2025–28 strategic plan; development of the 2024–25 business plan; strengthening and advancing equality and human rights in Wales; and diversity in public appointments. The Committee also undertook an effectiveness review.

The Wales Commissioner was regularly in contact with Welsh Government Ministers, including the Minister for Equalities and Social Justice. Meetings also took place with The Older Peoples Commissioner, The Children’s Commissioner and The Future Generations Commissioner, as well as a range of other senior stakeholders.

Wales Committee formal meeting attendance

Name	Attendance / eligibility
Wales Commissioner, Eryl Besse (Chair until 31 October 2023)	3/3
Martyn Jones (Acting Chair from 2 November 2023)	4/5
Mark Sykes	3/4
Bethan Thomas[footnote 3]	3/5
Chris Dunn	5/5
Helen Mary Jones	2/5
Mary van den Heuvel	4/5

More information about the Wales Committee and its work is on our website.

Audit and Risk Assurance Committee

The Audit and Risk Assurance Committee (ARAC) supports the Board, and the Chief Executive as Accounting Officer, by providing independent advice and challenge to give assurance that governance arrangements, risk management approaches and control frameworks are in place and effective. The Committee operates in line with the

guidance and good practice principles set out in HM Treasury’s ‘Audit and Risk Assurance Committee Handbook’ (March 2016) and the Cabinet Office’s “Code of Conduct for Board Members of Public Bodies” (June 2019).

The ARAC held five formal meetings during 2023–24 and is chaired by Kunle Olulode, Commissioner.

In 2023–24, the ARAC considered financial and operational performance, risk management, compliance with policy, internal audit reports and progress with audit recommendations.

ARAC formal meetings attendance

Name	Attendance / eligibility
Commissioners	-
Kunle Olulode (Chair)	5/5
Jessica Butcher	1/1
Su-Mei Thompson	3/3
Joanne Cash	4/4
Independent members	-
Gill Eastwood	5/5
Charlotte Moar	5/5

More information about the ARAC can be found on our website

People and Workspace Committee

The People and Workspace Committee (P&WC) provides advice and assurance on matters affecting employees, remuneration, infrastructure and environmental impact.

The P&WC held four formal meetings during 2023–24 and one additional meeting. It was chaired by Eryl Besse, Commissioner and Deputy Chair, until 27 September 2023, and by Joanne Cash, Commissioner, from 28 September 2023.

In 2023–24, the P&WC considered issues including culture and values, employee turnover, employee engagement, policies and guidance for our teams and managers, performance management, the Environment, Sustainability and Governance (ESG) statement and the EHRC’s Building our Commission programme.

The Committee also provided oversight strategic and operational delivery, such as our gender pay gap reporting, and risks including those relating to people, infrastructure and estates, and information governance.

P&WC meetings attendance

Name	Attendance / eligibility
Commissioners	-
Eryl Besse (Chair until 27 September)	2/2
Joanne Cash (Chair from 28 September)	4/5
Arif Ahmed	0/1
Akua Reindorf	5/5
Su-Mei Thomson	2/2
Lesley Sawers (co-opted from 23 November 2023)	2/2
Jessica Butcher	1/2
Independent member	-
Jonathan Parsons	5/5

Statement of Accounting Officer’s responsibilities

Under the Equality Act 2006, the Secretary of State, with the consent of HM Treasury, has directed EHRC to prepare for each financial year a statement of accounts in the form and on the basis set out in the Accounts Direction.

The accounts are prepared on an accruals basis and must give a true and fair view of the state of affairs of EHRC and of its income and expenditure, statement of financial position and cash flows for the financial year.

In preparing the accounts, the Accounting Officer is required to comply with the requirements of the Government Financial Reporting Manual, and in particular, to:

• observe the Accounts Direction issued by the Secretary of State, with the consent of HM Treasury, including the relevant accounting and disclosure requirements, and apply suitable accounting policies on a consistent basis
• make judgements and estimates on a reasonable basis
• state whether applicable accounting standards as set out in the Government Financial Reporting Manual have been followed, and disclose and explain any material departures in the financial statements
• prepare the financial statements on a going-concern basis
• confirm that the Annual Report and Accounts is as a whole, fair, balanced and understandable

Additionally, the Accounting Officer must confirm that they take personal responsibility for the Annual Report and Accounts, and the judgements required for determining that it is fair, balanced and understandable.

The Principal Accounting Officer of the Cabinet Office appoints the Acting Chief Executive as Accounting Officer of EHRC. The responsibilities of the Accounting Officer include the propriety and regularity of the public finances, for which the Accounting Officer is answerable, keeping proper records and safeguarding EHRC’s assets. These responsibilities are set out in ‘Managing Public Money’, published by HM Treasury.

As the Accounting Officer, I have taken all the steps that I ought to have taken to make myself aware of any relevant audit information and to establish that EHRC’s auditors are aware of that information. As far as I am aware, there is no relevant audit information of which the auditors are unaware.

Governance Statement

EHRC is a statutory non-departmental public body established by the Equality Act 2006. It is Britain’s national equality body, recognised as an ‘A’ status National Human Rights Institution by the Global Alliance of National Human Rights Institutions. It operates independently of government and Parliament.

I was appointed as Acting Chief Executive and Interim Accounting Officer from 1 April 2024, and was appointed to the role on a permanent basis on 23 August 2024. Prior to my appointment, the role of Accounting Officer was held by Marcial Boo from 23 September 2021 to 16 October 2023 and the role of Acting Accounting Officer from 17 October 2023 to 31 March 2024 was held by Cath Denholm. Cath Denholm received no formal letter of assurance from the previous Accounting Officer, however in her substantive role as Chief Operating Officer she received assurance through attendance at Board, the Audit and Risk Assurance Committee and from senior officers. I received a formal letter of assurance at the end of her Accounting Officer tenure. Having attended Board and ARAC meetings and having sought and received assurances from my senior officers, I am content that there were no outstanding issues to note in the period before my appointment as Interim Accounting Officer.

This Governance Statement, for which I, as Accounting Officer, take responsibility, is designed to give an understanding of our governance structure, internal controls and risk management processes and explains how assigned duties have been carried out during 2023–24.

Scope of Responsibility

I have responsibility for maintaining a system of internal control that supports the delivery of our policies, aims and objectives while safeguarding the public funds and our assets.

My role, supported by the Leadership Team and alongside the Board, includes ensuring that steps are taken to prevent and detect fraud, in accordance with the responsibilities assigned to me in ‘Managing Public Money’ and our Framework Document.

Corporate governance structures

Our corporate governance structures and information on how we are required to report to Parliament are set out in the Equality Act 2006.

The relationship with our sponsor department, the Cabinet Office, is agreed through a Framework Document, which contains details of my responsibilities as the Accounting Officer of EHRC.

The Framework Document is on our website. It was last updated in November 2019 and is currently being reviewed by the Equality Hub. Our Annual Report and Accounts are laid before Parliament by the Cabinet Office, and copies of the report are sent to the Scottish Parliament and the Senedd Cymru (Welsh Parliament).

More information about our corporate governance structures is on our website.

Board of Commissioners

Details of the Commissioners who served as members of the Board during 2023–24 are on page 65.

Commissioners are expected to demonstrate integrity, honesty, objectivity and impartiality in line with the (Nolan) Principles of Public Life. They are required to disclose any relationship that could be or be perceived to be a conflict when participating in Board decisions. We maintain a register of Commissioners’ interests. A declaration of interests is a standing item on Board agendas, with Commissioners reminded to keep the register up to date, and to declare any potential interests in advance of meetings.

The Commissioners’ register of interests is on our website.

The Board is responsible for setting overall corporate strategy, policy and annual business plans. The specific role, responsibilities and functions of the Board and its committees are set out in our Governance Manual, prepared in line with the Cabinet Office ‘Code of Best Practice for Board Members of Public Bodies’ and the UK government’s ‘Corporate Governance in Central Government Departments: Code of good practice’. Our Governance Manual, along with the Equality Act 2006 and our Framework Document, act as the Board’s terms of reference.

Our Governance Manual also includes our Commissioner and Committee Member Code of Conduct. This document outlines how we handle allegations and complaints against Commissioners and Committee Members. At the date of publication we have no investigations being handled through this process, however during 2023–24 we did conclude an investigation. This was a highly publicised event that tested the operational and cultural responsiveness and resilience of our processes. We were obliged to seek Cabinet Office and Ministerial advice in aspects of the investigation and in order to achieve the consensus of opinion now established both in how to respond to such events and how to embed a clarity in our procedures going forward.

To learn from these events and strengthen our policies and processes we commissioned an investigation into media leaks, an advisory internal audit of legal fees and a governance review. Recommendations from these exercises have been accepted and a new procedure for investigative expenditure has been agreed.

The Governance Manual is on our website.

The Corporate Governance Code was written for government departments rather than public bodies and advises having an ‘approximately equal number of ministers, senior civil servants, and non-executives’. Our Board contains no ministers and comprises non- executive Commissioners in accordance with the Equality Act 2006, which requires the Secretary of State to appoint a board of between 10 and 15 Commissioners. Members of the Board have a good balance of skills and experience to enable it to fulfil its responsibilities.

The minutes of Board meetings are on our website.

Board performance and effectiveness

The Board carries out an external review of effectiveness every three years. The last review was completed in July 2022, when a report on findings and recommendations was adopted by the Board. Substantial improvements to Board performance and effectiveness have now been made including:

• further strengthening performance reporting to the Board through an updated Chief Executive’s report
• reviewing and updating our meeting cycles to ensure a good flow of information and advice from Leadership Team and advisory committees to the Board
• creating more opportunities for members of the Board to connect with people across the organisation and with members of the advisory committees

An independent review of governance was commissioned by the Board in February 2024. The review reported back to the Board in May 2024 with a number of recommendations which are now being developed for implementation.

Senior Management

The role of senior management is to support the Chief Executive, particularly in their role as Accounting Officer, and the Board in the development and implementation of the corporate strategy and business plan, to provide leadership of staff, set work priorities, monitor performance and manage risk.

The Chief Executive is supported by the Leadership Team as the decision-making group that assists with the management of the organisation, its programmes, projects and regulatory activity.

The Leadership Team is chaired by the Chief Executive and meets on a weekly basis. In 2023–24 it included Chief Officers, Directors and functional leads with specific organisational responsibilities. It is responsible for:

• ensuring the effective management of the organisation including matters concerning EHRC as a whole, such as leadership strategies, culture, governance, relationships with key stakeholders, three nations approach, risk management and compliance with legal and other obligations
• ensuring the organisation’s business is delivered effectively and with impact, including the delivery of the strategic and business plans and the Annual Report and Accounts for onward referral to the Board for approval; resourcing and or/reprioritising work for existing and new programmes or projects and approving and identifying leads for leading new work
• leading and developing the organisation through a collective leadership approach, regular review of feedback and commitment to organisational improvement
• relationships with the Board and its Committees, including how matters are escalated, and responding to work requested by the Board

Project and programme management

We deliver a wide range of work from policy and research to legal casework and stakeholder influencing, focussing on maximising our impact with limited resources.

Given the complexity and visibility of much of our work, effective planning and project management is essential. In 2023–24 we built on our plan to deliver methodology which provides a framework for delivering projects that aligns with Government Functional Standards. Plan to deliver defines the process for managing change, project gateways, progress reporting and provides consistent artefacts for project delivery.

As part of our project methodology, EHRC has put in place a robust governance framework for change and project management to support delivery. Each area of focus under our strategic plan for 2022–2025 has a Programme Delivery Group (PDG) and an assigned Senior Responsible Owner (SRO). Each PDG meets monthly and provides the SRO with the opportunity to review all projects within their area of focus and make any amendments or changes and escalate any risks or concerns to Leadership Team and, in some cases, to the Board.

Information management

Information governance and the protection of assets containing personal and sensitive data are a priority for us. We have strong professional governance arrangements in place with a member of the Leadership Team acting as the Senior Information Risk Owner (SIRO) working closely with the Data Protection Officer (DPO) and we have appointed Data Owners and Data Champions in every team.

The SIRO chairs an Information Governance Steering Group that maintains oversight of data protection, information security and records management. A monthly report is presented to Leadership Team and an annual Information Governance Assurance Report goes to the Audit and Risk Assurance Committee.

During 2023–24, we:

• successfully processed a higher than usual volume of complex information requests, with less resource in the Information Governance team
• investigated all data incidents to assess risk and monitor patterns
• investigated leaks to the media with the resulting report fully agreed by the Board
• attended all team meetings to train staff, including encouraging the reporting of suspected incidents promptly and promoting good records management
• delivered bespoke subject access request training for commissioners
• facilitated workshops with all Data Owners and Data Champions to review Information Asset Registers, share good practice and consult on developments
• worked with the National Archives to start to dispose of records of legacy commissions. With this, we recognise that we need to further work on our Public Records Act compliance, and potentially also with our GDPR compliance in case some of the records contain personal data that has met its retention period.
• ensured data protection involvement in key projects, including security and records management improvements as part of the Microsoft 365 project, including beginning to implement SharePoint
• updated privacy notices, policies, procedures, technical and organisational security controls

Personal data incidents

Between 1 April 2023 and 31 March 2024, twelve data breaches were reported (four in 2022–23). Most incidents were categorised as ‘no impact’ or ‘low impact’ apart from one ‘high impact’ incident involving information widely reported in the media. Three incidents, including the ‘high impact’ incident, were reported to the Information Commissioner’s Office (ICO) but did not result in any action being taken by the ICO. All incidents were investigated, and lessons learned.

Freedom of information requests

During 2023–24, we received 168 requests under the Freedom of Information Act 2000 (156 in 2022–23). Of those requests, 99% received a response within the statutory deadline. 17 requests were the subject of internal review. Three requests were appealed to ICO. Of these, one was found in our favour; one was closed as we voluntarily released the information; and one is still open. Two claims were made to the First Tier Tribunal (Information Rights); one was found in our favour; and one partially found in our favour, requiring us to disclose part of the information requested.

Internal complaints and grievances

It is important that all workers of EHRC, including employees, contractors, Commissioners and Committee members, can raise concerns about the standards of service we provide or the behaviour of other staff in delivering that service.

Our people can submit a complaint or grievance using our Dispute Resolution Policy and Procedure or by using our Anti-Bullying and Harassment Policy and procedure. All complaints and grievances are managed in line with the appropriate procedure.

During 2023–24, we received two formal internal complaints, both of which have been concluded.

We successfully defended an employment tribunal claim made by a former employee. A further claim was allowed in error by the Tribunal service and was subsequently withdrawn. We have no outstanding employment tribunals claims.

External complaints

In 2023–24 we received 16 complaints from outside the organisation (14 in 2022–23). The table below provides a summary of the outcome of these complaints. All complaints were dealt with satisfactorily by our internal procedures.

Decision	Number of complaints
Referred to the Parliamentary and Health Service Ombudsman	0
Resolved on receipt / at first point of contact	3
Upheld	1
Partly Upheld	0
Not Upheld	5
Rejected / Withdrawn	7

More information about our complaints policy is on our website.

Internal whistleblowing

Our whistleblowing policy is available to all staff on our intranet and sets out the steps staff should take to raise their concerns about behaviours and practices at the EHRC. The policy is supported by detailed guidance on the procedures to follow when raising these concerns. No whistleblowing disclosures were made during 2023–24.

External whistleblowing

As a Prescribed Whistleblowing Body^{[footnote 4]}, our mandate is to provide workers who are concerned that their employer is breaching equality and human rights law with a mechanism to make a disclosure to an independent body when they feel unable to disclose directly to their employer.

Every disclosure is recorded, and the information disclosed is assessed to help us decide whether to look more closely at an organisation’s compliance with equality and human rights law and whether to take regulatory action.

Further information on whistleblowing and how we deal with concerns reported to us is on our website.

Correspondence

Our correspondence function forms an integral part of the public face of the EHRC. We receive and respond to emails, letters and phone calls from individuals, organisations, MPs, parliamentarians and stakeholders requesting information, advice, legal support and regulatory action on a wide range of issues.

In 2023–24, the total number of written and phone correspondence queries we received was 4,174, we responded to 4,007 (96%) within our target response time of twenty working days. This compares to 4,530 total correspondence queries in 2022–23, when we responded to 4,227 (93%) within the same target time of 20 working days.

Donations

We did not make any charitable or political donations in this year.

Internal control

We have a comprehensive framework of procedures and controls which cover financial and non-financial processes. This framework is regularly reviewed to ensure that it complies with all current requirements and is tested as part of the internal audit work programme. We have developed a new a compliance programme during in 2023–24 which will review all internal controls and update make recommendations them for updates or improvements where needed. This programme has been developed with consideration of the requirements of Government Functional Standards.

As the Accounting Officer, I have responsibility for our financial affairs, subject to limits delegated to me by the Principal Accounting Officer and outlined in the Framework Document. I delegate resource and capital budgets to our directors based on the receipt of a business plan for their areas of responsibility.

The scheme of delegation underpins the financial delegations contained in the Framework Document. The scheme enables budget holders to make decisions and holds them accountable for the effective management of their delegated budget, the decisions they make and the delivery of their work plan against agreed milestones. Budget holders are required to report on their performance on a monthly basis to the Leadership Team.

Performance information is subject to further periodic scrutiny and review by the Board and the ARAC. They are provided with information to enable them to function effectively. Strategic risks and issues considered by senior management are escalated to the Board, with agreed management action where appropriate.

Government functional standards

Functional standards mandated for use across central government exist to create a coherent, effective and mutually understood way of doing business within government organisations and across organisational boundaries, and to provide a stable basis

for assurance, risk management and capability improvement. In 2023–24, we carried out further work to ensure our procedures continued both to meet HMT’s mandatory compliance requirements and satisfied our own needs as a non-departmental public body.

Work has begun on developing our own operational service manual which forms part of a wider internal compliance programme in which we are reviewing all relevant Commission policies, processes and procedures to ensure their alignment with current legislation and best practice.

Fraud

A counter-fraud policy is in operation which aligns with government requirements. Staff are always expected to act with integrity and to safeguard the public resources for which they are responsible.

There were no cases of fraud identified in 2023–24.

Conflicts of interest

The governance framework sets out the rules and guidance for Commissioners and Committee members on conflicts of interests and we maintain a publicly available register of Commissioners’ interests. All appointees are required to complete a declaration and to notify EHRC of any changes to their declaration as soon as they occur. Attendees are required to declare any potential conflicts at the beginning of meetings and individuals are required to recuse themselves from relevant items.

The staff Code of Conduct requires staff to declare all interests, including paid and unpaid external roles which may (or may be perceived to) conflict with their role in the organisation. The Code explains the actions that staff need to take to excuse themselves from any activity where their interest may be perceived as influencing their judgement.

The Code explains that it is the employee’s responsibility to keep their information up to date and accurate. Declarations returned are recorded, reviewed and assessed. Staff are reminded by direct communication, on an annual basis, and by line managers, about their responsibility to complete a declaration of interest return.

We have reviewed the declarations received during 2023–24 and are satisfied that no employees of the organisation hold external roles that present a conflict of interest to EHRC.

Auditing of Accounts

The National Audit Office carries out our external audit on behalf of the Comptroller and Auditor General.

Risk Management

The Board is responsible for oversight and management of risk at the EHRC. This includes ensuring that effective arrangements are in place to provide assurance on risk management, good governance and internal control.

The Board agrees an overall risk framework sets the strategy, policy for the management of risk and the strategic risk appetite for the EHRC and has final approval and oversight of the Strategic Risk Register. This is supported by oversight and advice from the Executive, ARAC and P&WC.

The executive base our approach to risk management on collective accountability, with risks and mitigating actions identified and owned by those best placed to manage them. Risks are scored according to their likelihood and impact and monitored in line with their severity. Conversations on risk take place on a monthly basis at the Leadership Team meetings to ensure effective mitigations are in place, and at ARAC each quarter. Risk is reported to Board twice a year.

The Commission has identified seven strategic risks which inform the corporate risk register and management of risk. The seven strategic risks are:

• External environment – that EHRC is not sufficiently aware of external issues and does not feed appropriate intelligence into decision making with a consequential impact on effectiveness and reputation.
• Stakeholder relationships – that EHRC does not engage effectively with stakeholders, failing to inform, persuade or influence them appropriately and consequently losing their confidence, resulting in loss of funding, status or adverse impact on delivery.
• Mission and strategy – that EHRC does not have an effective process for arriving at the right strategy and policy commensurate with its remit, with the consequence that it does not deliver what is needed to fulfil its remit.
• Delivery – that EHRC does not deliver the outcomes in its strategic plan with the result that it does not fulfil its remit and suffers reputational damage.
• People – that EHRC does not have people with the right skills and does not use them well. Including culture, leadership, structure, skills, experience, workload, recruitment and retention.
• Change and improvement – that EHRC does not recognise and manage the need for change well, resulting in poor staff engagement and lost opportunity in delivering organisational improvements.
• Governance and compliance – that EHRC does not comply with all required public governance standards, protections and law, and fails to benefit from best practice standards resulting in loss of productivity or reputation.

Risks identified and managed through the corporate risk register during 2023–24 spanned the seven strategic areas agreed by the Board. They related to the internal and external and internal issues of greatest concern for the ongoing delivery of our strategic plan for 2022–25. Key drivers of risk in 2023–24 were:

• the contentious nature of the issues with which we are engaged, such as sex and gender, race equality and the balance of rights, and the variety of expectations of us among stakeholders
• the impact of uncertainty in the political environment with the impending, and now called, General Election and with changes in First Minister in both Scotland and Wales
• challenge to our international standing from the sub-committee on Accreditation (SCA) through their special review of the Commission’s NHRI status
• the impact of continued real-term budget reductions on our capacity, capability and ability to deliver
• the impact of public scrutiny, including that caused by media leaks on our reputation; and
• the impact of departures by senior leaders in both the Executive and the Board on consistency and continuity of leadership

In 2023–24, we identified and tracked a total of 14 corporate risks. The register opened with 13 risks and one new risk was identified in year. The new risk identified related to external challenge with a particular focus on the Sub-committee on Accreditation (SCA) special review of the Commission’s NHRI status. This risk has now reduced with the sub- committee reconfirming our ‘A’ status.

Risk trends across 2023–24 were varied with five risks remaining static in scoring or returning to the same scoring as initially registered, three risks increased in scoring over the course of the year and six risks decreased in score.

Many of the key mitigations of risks to delivery are already identified through our performance report. Some specific actions include:

• development and publication of our Equality and Human Rights Monitor, in line with our statutory responsibility
• maintaining our regular engagement with UK, Scottish and Welsh governments and with other stakeholders, however well-disposed they are towards us or our actions
• engaging internationally in our capacity as an NHRI including engaging positively with the SCA special review process, which resulted in our NHRI ‘A’ status being reconfirmed
• engaging teams, the executive and the Board in prioritisation and decision-making for the 2024–25 business plan to ensure that it aligns with our existing strategy and lays the groundwork for the next strategic plan
• prioritising activity in-year, ensuring that we delivered over 80% of our business plan within the budget we had available and respond to external and internal changes
• recruitment to senior roles to ensure leadership capacity
• investment in our people, including managers and senior leaders through the launch of leadership and management development for all levels of management in the organisation and developing mutual mentoring programmes

Our governance and compliance controls are tested through the internal audit programme and informed by internal reviews. All audits found reasonable or substantial assurance

in controls. More information about our internal audit outcomes can be found on pages 86–87. We draw considerable assurance from the assurance on the reliability of our systems for managing risk that those audit reports provide.

Accounting Officer’s assurance

As Accounting Officer, I have responsibility and accountability for EHRC, its management, the efficient use of public funds and stewardship of its assets. I have responsibility for ensuring that EHRC has systems of governance, risk management and internal control in place and I am responsible for reviewing the effectiveness of these systems.

The system of internal control reflects good practice. It identifies and manages risk, rather than eliminate all risk of failure. It provides reasonable but not absolute assurance of effectiveness, supporting the achievement of our aims and objectives, while safeguarding our funds and assets, in line with ‘Managing Public Money’. These controls have been in place throughout 2023–24 and up to the date of approval of the Annual Report and Accounts and accord with Treasury guidance.

My review of effectiveness is informed by assurances received from the Leadership Team throughout the year and from the work carried out by ARAC. It is further supported by the assurance received from internal and external audit opinions.

Assurance provided by delegated budget holders

Budget holders are required to confirm that they understand the terms of the delegation, their limits of authority and responsibilities and that they are aware of all controls in place.

Budget holders are required to complete an annual assurance statement that confirms that they have met all their obligations or made me, as Accounting Officer, aware of any instances where controls have not been met in the following areas:

• management of delegated financial resources
• managing staff performance
• risk identification and management
• audit arrangements

Budget holders are also required to make me aware of any contingent liabilities or potential claims against EHRC that have not been disclosed elsewhere. I am assured that, on review of the returns received, that there is nothing of this nature that needs to be brought to the attention of the auditors.

Assurance provided by the ARAC

The ARAC provides independent oversight and review of processes and policies to give assurance that our governance arrangements are appropriate and are operating effectively.

The ARAC completed its programme of work for the year and, in addition to reporting to the Board, has produced an annual report of its work for my and the Board’s consideration. ARAC has not identified any additional issues requiring disclosure than those already noted in this report.

The Chair of the ARAC has provided the following statement:

We have an effective Audit and Risk Assurance Committee (ARAC). ARAC Members possess a range of skills and experience and provide valuable insight and scrutiny. Throughout the year, the ARAC has worked with EHRC’s Executive Leadership Team and other officers to ensure that adequate controls are in place.

ARAC received regular reports from management on financial performance, risk and relevant policies, including plans to improve and strengthen compliance with these controls. ARAC received strong assurance on the organisation’s approach to information governance and received regular updates to confirm whether there were any fraud or whistleblowing issues, with no concerns arising. We maintained a strong focus on improving governance procedures, particularly risk management, internal compliance and assurance processes. The ARAC will continue to scrutinise and seek assurance from the executive during 2024–25 that those frameworks put in place by management continue to be effective.

ARAC engaged with EHRC’s internal and external auditors throughout the year. We reviewed the internal audit plan and all reports received. The work from our internal audit provider continues to run smoothly, with all reports received as planned and constructive working relationship reported between the audit service and staff.

The ARAC Chair reported to the Board at each meeting and provided assurance on matters such as risk management, governance and internal controls. ARAC is therefore of the opinion that control systems are in place and have, for the most part, performed adequately. This is supported by the outcomes of our internal audits throughout the year, specifically those relating to financial reporting and budgetary control and procurement and contract management, which both received substantial assurance ratings. Our risk management, change management and performance management audits all received a reasonable assurance rating. More information about this can be found on page 87. Members of the ARAC noted ongoing focus on ensuring that the organisation’s policies are comprehensive and up-to-date.

The ARAC notes that there have been issues during the year relating to the management of internal investigations and an incident of external disclosure of confidential information. A separate advisory audit identified recommendations to improve the monitoring of expenditure commissioned by Board members.

Over the course of 2023–24 there were periods of time where the full complement of Commissioners was not part of the ARAC as outlined in in its terms of reference. This was due to an approved sabbatical for one Commissioner who was also a member of the ARAC. However, the committee was quorate at all meetings.

During the period of this Annual Report and Accounts, EHRC has had three Accounting Officers. The ARAC are satisfied that each of the Accounting Officers was aware of any issues and that necessary action has been taken during the year to respond to and manage them. Members of the ARAC have supported each Accounting Officer during

2023–24 in handling these issues and have offered appropriate and relevant advice to the Board, in particular about associated risks.

Assurance provided by the annual internal audit opinion

Internal Audit

TIAA acted as our internal auditor during 2023–24. The internal audit plan which is approved by the ARAC is designed to provide independent assurance on our governance, risk management and internal controls. Audits agreed as part of the annual plan are carried out in accordance with the guidance contained in the Public Sector Internal Audit Standards. The internal auditor reports on findings, provides comparators to similar organisations and makes recommendations to management, who develop and agree an action plan to address any weaknesses identified.

The audit plan for 2023–24 included 90 days of audit time. A total of seven reviews were conducted, six of which were designed to determine the extent to which the internal control system is adequate to ensure that activities and procedures are operating to achieve the EHRC’s objectives. There was also an advisory audit undertaken which replaced a planned governance audit on strategic planning which will now take place in 2024–25.

Of the six audits provided with a level of assurance, two were rated as ‘substantial’, meaning that “there is a robust system of internal controls operating effectively to ensure that risks are managed, and process objectives achieved,” and four as ‘reasonable’, where “the system of internal controls is generally adequate and operating effectively but some improvements are required to ensure that risks are managed, and process objectives achieved”.

Recommendations have been made based on the findings of the audit work, but no fundamental control weaknesses, where limited or no assurance could be given, were identified.

From the reports received, there were three urgent recommendations, two important recommendations and ten routine recommendations. All the recommendations received have been reviewed by management and actions agreed.

The following areas were reviewed and reported on as part of the 2023–24 plan, outcomes are also included in the table below:

System	Assurance assessment
Governance – change management	Reasonable
Risk management framework and mitigating controls	Reasonable
Financial reporting and budgetary controls	Substantial
Procurement and contract management	Substantial
Performance management	Reasonable
Human resource management	Reasonable
Investigation costs	N/A – Advisory only

ARAC received reports from the internal auditor on each review and a progress report from management on actions to implement recommendations. The internal audit process is managed on behalf of EHRC through our finance team.

The internal auditors provide an annual report which summaries the outcomes of audits carried out during the year and provides an annual opinion. As Accounting Officer, I review the audit reports received and the recommendations made and ensure that maintaining and improving effective governance remains a key priority for management and that any recommendations made by the internal auditors are acted upon.

This year, based on their audit work, the head of internal audit issued the following opinion:

‘TIAA is satisfied that, for the areas reviewed during the year, Equality and Human Rights Commission has reasonable and effective risk management, control and governance processes in place’.

Accounting Officer’s conclusion

I have considered the evidence provided during the production and review of the Annual Governance Statement and the independent advice and assurance provided by ARAC. I am content that a good system of internal control, which was robust and fit for purpose, including the maintenance of an appropriate structure for managing risk, was in place for the year ended 31 March 2024.

Considering the assurances that I have received along with other evidence available to me, I conclude that we have satisfactory governance and risk management systems in place with effective plans to ensure continuous improvement of our control framework.

I confirm that this Annual Report and Accounts is fair, balanced and understandable. I take responsibility as Accounting Officer for the judgements made to ensure that it is fair, balanced and understandable.

John Kirkpatrick

Chief Executive and Accounting Officer

10 September 2024

Remuneration and staff report

This section provides details of the remuneration (including any non- cash remuneration) of Commissioners, independent members, the Chief Executive and Senior Directors. The content of the tables where indicated and the fair-pay disclosure are subject to audit.

Remuneration of Board members

Commissioners are appointed by the Minister for Women and Equalities, initially for a term of between two and five years and may be reappointed for one additional period.

The daily remuneration rates are set by the Minister. Board members are expected to work up to the number of days^{[footnote 5]} on EHRC business as prescribed in their letter of appointment. Any additional days for which fees are claimed must be approved by the Chairwoman in advance. Fees are paid in 12 equal instalments across the year and appointments are not pensionable.

Commissioners attend formal and informal meetings of the Board, support specific programmes of work and committees, represent EHRC at external events and attend training or developmental events as required.

Commissioners and Committee members can claim travel and subsistence expenses or request that travel is booked on their behalf when working on EHRC business. The expenses in the tables below show the total of out-of-pocket expenses claimed directly and travel and accommodation booked by EHRC for attendance at meetings. HMRC guidelines class any travel to Board meetings held at our London office as ‘commuting’, and any expenses claimed, or travel provided in relation to these meetings are subject to tax and National Insurance. EHRC meets the resultant tax liability for these expenses.

a) Chair & Commissioners’ pay summary (the information in tables b, c, and d is subject to audit)

Category	2023–2024 £000	2022–2023 £000
Board members’ fees (tables b, c, and d)	159	171
Board members’ employer’s National Insurance contributions (NICs) (tables b, c, and d)	11	11
Statutory and advisory committee members’ fees (table e, and f)	38	41
Total	208	223

The above table is a summary of emoluments disbursed. Further detail is shown in the following tables.

b) Chair

Baroness Kishwer Falkner was appointed as Chairwoman effective from 1 December 2020 for a period of four years.

Category	2023–2024	2022–2023
Chairwoman’s fees £	50,000	50,000
Employer’s NICs £	5,645	5,943
Total	55,645	55,943
Expenses and travel costs £	16,615[footnote 6]	1,081

c) Deputy Chairs

Category	Fees £ 2023–24	Fees £ 2022–23	Expenses and travel costs £ 2023–24	Expenses and travel costs £ 2022–23
Lesley Sawers Appointed Interim Deputy Chair from 28 September 2023	11,892	–	3,514	–
Eryl Besse Appointed 16 January 2023 – resigned as deputy chair 27 September 2023	11,508	4,728	–	–
Alasdair Henderson Appointed 16 January 2023 – resigned as deputy chair 27 September 2023	11,508	4,728	295	–
Caroline Waters Reappointed for a five-year term from 15 January 2018 – term ended January 2023	–	18,448	–	244
Subtotal	34,908	27,904	3,809	244
Employer’s NICs paid on fees and Expenses	3,033	2,401	–	–
Total	37,941	30,305	3,809	244

d) Fees and expenses for each Commissioner

Category	Fees £ 2023–24	Fees £ 2022–23	Expenses and travel costs £ 2023–24	Expenses and travel costs £ 2022–23
Arif Ahmed Appointed 3 January 2023 for an initial four-year term (resigned 11 August 2023)	3,635	2,500	153	71
Eryl Besse[footnote 7] Appointed 01 April 2022 for an initial four-year term (resigned 31 October 2023)	1,099	9,493	–	171
Jessica Butcher Appointed 1 December 2020 for an initial four-year term	10,000	10,000	501	160
Joanne Cash[footnote 8] Appointed 16 January 2023 for an initial four-year term	11,000	2,105	753	–
David Goodhart Appointed 1 December 2020 for an initial four-year term	10,000	10,000	263	98
Alasdair Henderson[footnote 9] Reappointed 27 April 2022 for an additional four-year term	5,082	11,708	110	542
Kunle Olulode Appointed 3 January 2023 for an initial four-year term	12,000	2,500	701	–
Akua Reindorf Appointed 20 December 2021 for an initial four-year term	10,000	10,000	420	253
Dr Lesley Sawers[footnote 10] Reappointed 29 March 2021 for an additional four-year term	5,901	12,000	2,702	1,005
Su-Mei Thompson[footnote 11] Appointed 1 December 2020 for an initial four-year term	5,833	10,000	199	612
Suzanne Baxter Appointed 27 April 2018 for an initial four-year term (term ended 26 April 2022)	–	833	–	–
Pavita Cooper Appointed 27 April 2018 for an initial four-year term (term ended 26 April 2022)	–	833	–	–
Helen Mahy Reappointed 27 April 2022 for an additional four-year term (resigned 4 March 2023)	–	11,099	–	68
Subtotal	74,550	93,071	5,802	2,980
Employer’s NICs paid on fees and Expenses	2,109	2,627	–	–
Total	76,659	95,698	5,802	2,980

Expenses in the above tables include travel and subsistence costs paid for by individual Commissioners and re-claimed from EHRC as expenses in line with the expenses policy. The totals also include the cost of any travel and accommodation booked directly by the EHRC on behalf of Commissioners when they are required to travel to attend meetings or events; these costs are not reimbursed to the individual.

e. Committee fees and expenses (summary)

Committee members are remunerated at a rate of £250 per day and are expected to work 12 days per annum (total fees £3,000 per annum). Members are expected to attend Committee meetings, to meet EHRC staff to support programmes or projects and to represent EHRC at external events.

Category	Fees £ 2023–24	Fees £ 2022–23	Expenses and travel costs £ 2023–24	Expenses and travel costs £ 2022–23
Scotland Committee	12,906	19,357	141	63
Wales Committee	18,854	17,063	614	35
Total (Scotland and Wales)	31,760	36,420	755	98
Employer’s NICs paid	–	–	–	–

During 2023–24, the Scotland Committee consisted of one member who was paid fees of £3,000 for the whole reporting period. One member’s term ended on 3 January 2024, they received 9 months fees £2,250; one member resigned on 8 June 2023 and received fees of £566; one member resigned on 11 August 2023 and received fees of £1,090. Four members joined the Committee on 1 October and each received fees of £1,500.

During 2022–23, the Scotland Committee consisted of three members who were paid fees of £3,000 each for the whole reporting period. One member resigned on 30 April 2022 and received fees of £250 up to this date. One member’s term ended on 31 December and received fees of £2,250. Two terms ended on 31 January, with both members paid total fees of £2,500. One member had a short unpaid period whilst their appointment was extended, reducing fees paid from £3,000 to £2,857.

During 2023–24 the Wales Committee consisted of four members who were paid £3,000 each for the whole of the reporting period, one member whose term ended on 31 January 2024 received fees of £2,500. Following the resignation of the Wales Commissioner, Martyn Jones was allocated additional days and received fees totalling £4,354.

During 2022–23 the Wales Committee consisted of four members who were paid £3,000 each for the whole reporting period. Three members resigned during the reporting period and received total fees of £2,063. Two new members were appointed in October 2022 and were paid £1,500 each from the date of appointment.

f. Fees and expenses for Committee independent members

ARAC and P&WC independent members receive an allowance of £250 per day and are expected to work a minimum of eight days per year (total fees (£2,000).

Category	Fees £ 2023–24	Fees £ 2022–23	Expenses and travel costs £ 2023–24	Expenses and travel costs £ 2022–23
Charlotte Moar (ARAC) Appointment extended until 30 September 2024	2,000	2,000	867	225
Gill Eastwood (ARAC) Appointment extended until 30 September 2025	2,000	2,000	1,097	548
Jonathan Parsons (P&WC) Appointed November 2022 for an initial two-year term	2,000	667	678	9
Total	6,000	4,667	2,642	782
Employer’s NIC	30	–	–	–

Staff pay and pension arrangements

Remuneration policy

The Equality Act 2006 details our authority to remunerate employees. We are responsible for the payment of any deductions from pay to the appropriate body and subject to HMT pay remit guidance when making any annual pay increases.

The reward package of senior managers (the Chief Executive and the Senior Directors) is reviewed by the People and Workspace Committee (P&WC) annually.

The following section contains details of the remuneration and pension interests of senior managers.

The Chief Executive and all permanently employed Senior Directors have employment contracts with require a three-month notice period.

There are no elements of the remuneration package that are not cash.

Salary and pension entitlements of senior officers (this information is subject to audit)

The following section provides details of the salary, pension entitlements and any taxable benefits in kind of our senior officers for the period to 31 March 2024.

Salary

Salary includes gross salary, performance pay or bonuses, overtime, reserved rights to London weighting or London allowances, recruitment and retention allowances and any other allowance to the extent that it is subject to UK taxation.

Non-consolidated award (bonus)

Bonuses paid are based on performance levels achieved against agreed objectives and are awarded on a team or individual basis. Bonuses for 2023–24 have been accrued and will be paid during the 2024–25 financial year following discussion with the trade unions.

Benefits in kind

The monetary value of benefits in kind covers any benefits provided and treated by HM Revenue and Customs as a taxable emolument. No benefits in kind were paid in 2023–24 (none in 2022–23).

Remuneration (salary, benefits in kind and pensions) – this information has been subject to audit

Single total figure of remuneration

Category	Salary £000 (bands of £5,000)	Bonus £000 (bands of £5,000)	Benefits in kind (rounded to nearest £100)	Notional pensions benefits[footnote 12] £000 (to the nearest £1,000)	Total £000 (bands of £5,000)
Marcial Boo[footnote 13], Chief Executive	–	–	–	–	–
2023–24	95–100 FYE 130–135	–	–	–	95–100
2022–23	125–130	–	–	49	175–180
Melanie Field[footnote 14], Chief Strategy and Policy Officer	–	–	–	–	–
2023–24	60–65 FYE 100–105	0–5	–	–	65–70
2022–23	95–100	–	–	(49)	45–50
Cath Denholm[footnote 15], Chief Operating Officer, Acting Chief Executive from 13 October 2023	–	–	–	–	–
2023–24	To 1 October 23 50–55 FYE 100–105 From 2 October 23 65–70 FYE 130–135	0–5	–	–	115–120
2022–23	95–100	–	–	39	135–140
John Kirkpatrick[footnote 16], Deputy Chief Executive	–	–	–	–	–
2023–24	45–50 FYE 105–110	–	–	–	45–50
2022–23	–	–	–	–	–
Jacqueline Killeen[footnote 17], Chief Regulator	–	–	–	–	–
2023–24	20–25 FYE 90–95	–	–	–	20–25
2022–23	65–70 FYE 90–95	–	–	33	100–105

Pay multiples (this information has been subject to audit)

Reporting bodies are required to disclose the relationship between the remuneration of the highest-paid director in their organisation and the median remuneration of the organisation’s workforce.

Total remuneration includes salary and allowances, non-consolidated performance- related pay and benefits in kind. It does not include severance payments, employer pension contributions or the cash equivalent transfer value (CETV) of pensions.

Full-time equivalent (FTE) is defined as actual hours worked as a proportion of a full working week (36 hours).

For the purposes of calculating the pay ratio, we have estimated the annual remuneration paid to interim staff, as this information is not available. The calculation is based on an estimate on 222 working days at the interim’s agency day rate (excluding VAT) less 30% to cover agency fees and employer’s NICs.

Category	2023–24 Including bonus payments	2022–23 Including bonus payments	2023–24 Excluding bonus payments	2022–23 Excluding bonus payments
Banded remuneration of the	130,000 –	125,000 –	130,000 –	125,000 –
highest-paid director £	135,000	130,000	135,000	130,000
First quartile of pay £	42,228	40,226	42,228	40,160
First quartile ratio %	3.14	3.17	3.14	3.17
Median total remuneration £	43,728	41,025	42,228	40,160
Median pay ratio %	3.03	3.11	3.14	3.17
Third quartile of pay £	55,000	52,184	53,500	51,319
Third quartile ratio %	2.41	2.44	2.48	2.48
Range of banded remuneration for employees £	25,000 – 30,000 to 13,000 - 135,000	20,000 – 25,000 to 125,000 - 130,000	25,000 – 30,000 to 130,000 - 135,000	20,000 – 25,000 to 125,000 - 130,000

There were also no bonuses or benefits paid to the highest paid director in either year.

The banded remuneration of the highest-paid director in the financial year 2023– 24 was £130,000 to £135,000 (2022–23 £125,000 to £130,000) including bonus payments. This was:

• 3.14 times (2022–23, 3.17 times) the first quartile of remuneration, which was £42,228 (2022–23 £40,226)
• 3.03 times (2022–23, 3.11 times) the median remuneration of the workforce, which was £43,728 (2022–23, £41,205)
• 2.41 times (2022–23 2.44 times) the third quartile of remuneration, which was £55,000 (2022–23 £52,184)

In 2023–24 no employee, (2022–23, none) received remuneration in excess of that received by the highest paid director.

The percentage change in respect of the highest paid director is 4% (no change in 2022– 23). In essence, the ratios highlight an immaterial change in pay for 2023–24, and that the median pay is consistent with the Civil Service Pay Remit guidance for 2023 to 2024.

Change in total remuneration

Category	2023–24	2022–23	Change	% Change
Average pay Including bonuses £	49,814.67	46,993.54	2,821.14	6.00
Average pay excluding bonuses £	48,568.34	46,401.39	2,166.95	4.67
Average bonus payment £	1,217.51	592.15	625.36	105.61
No of employees receiving a bonus	186	220	-34	-15.45

Average remuneration for all staff excluding bonuses increased by 4.67 per cent. This increase is attributed to a combination of the pay award and a change in the grade mix of the workforce.

The average bonus payment increased whilst the number of recipients decreased, due to a lower number of staff qualifying for bonuses in 2023–24 compared to 2022–23. The percentage increase in bonus includes the Cost of Living^{[footnote 18]} allowance payments ranging from £750 to £1,500. There are ongoing negotiations regarding an end of year non- consolidated bonus payment for 2023–24.

Pension benefits – this information has been subject to audit

Accrued pension at pension age as at 31 March 2024 and related lump sum (bands of £5,000)	Real increase in pension and related lump sum at pension age (bands of £2,500)	CETV at 31 March 2024 £000	CETV at 31 March 2023 £000	Real increase in CETV £000
Marcial Boo, Chief Executive
–	–	–	341	–
Melanie Field, Chief Strategy and Policy Officer
–	–	–	1,050	–
Cath Denholm, Chief Operating Officer
–	–	–	83	–
John Kirkpatrick, Deputy Chief Executive
–	–	–	–	–
Jacqueline Killeen, Chief Regulator
–	–	–	518	–

Accrued pension benefits for directors are not included in this table for 2023/24 due to an exceptional delay in the calculation of these figures following the application of the public service pensions remedy.

Civil Service pensions

Pension benefits are provided through the Civil Service pension arrangements. Before 1 April 2015, the only scheme was the Principal Civil Service Pension Scheme (PCSPS), which is divided into a few different sections – classic, premium, and classic plus provide benefits on a final salary basis, whilst nuvos provides benefits on a career average basis. From 1 April 2015 a new pension scheme for civil servants was introduced – the Civil Servants and Others Pension Scheme or alpha, which provides benefits on a career average basis. All newly appointed civil servants, and the majority of those already in service, joined the new scheme.

The PCSPS and alpha are unfunded statutory schemes. Employees and employers make contributions (employee contributions range between 4.6% and 8.05%, depending on salary). The balance of the cost of benefits in payment is met by monies voted by Parliament each year. Pensions in payment are increased annually in line with the Pensions Increase legislation. Instead of the defined benefit arrangements, employees may opt for a defined contribution pension with an employer contribution, the partnership pension account.

In alpha, pension builds up at a rate of 2.32% of pensionable earnings each year, and the total amount accrued is adjusted annually in line with a rate set by HM Treasury. Members may opt to give up (commute) pension for a lump sum up to the limits set by the Finance Act 2004. All members who switched to alpha from the PCSPS had their PCSPS benefits ‘banked’, with those with earlier benefits in one of the final salary sections of the PCSPS having those benefits based on their final salary when they leave alpha.

The accrued pensions shown in this report are the pension the member is entitled to receive when they reach normal pension age, or immediately on ceasing to be an active member of the scheme if they are already at or over normal pension age. Normal pension age is 60 for members of classic, premium, and classic plus, 65 for members of nuvos, and the higher of 65 or State Pension Age for members of alpha. The pension figures in this report show pension earned in PCSPS or alpha – as appropriate. Where a member has benefits in both the PCSPS and alpha, the figures show the combined value of their benefits in the two schemes but note that the constituent parts of that pension may be payable from different ages.

When the Government introduced new public service pension schemes in 2015, there were transitional arrangements which treated existing scheme members differently based on their age. Older members of the PCSPS remained in that scheme, rather than moving to alpha. In 2018, the Court of Appeal found that the transitional arrangements in the public service pension schemes unlawfully discriminated against younger members.

As a result, steps are being taken to remedy those 2015 reforms, making the pension scheme provisions fair to all members. The public service pensions remedy6 is made up of two parts. The first part closed the PCSPS on 31 March 2022, with all active members becoming members of alpha from 1 April 2022. The second part removes the age discrimination for the remedy period, between 1 April 2015 and 31 March 2022, by moving the membership of eligible members during this period back into the PCSPS on 1 October 2023. This is known as ‘rollback’.

For members who are in scope of the public service pension remedy, the calculation of their benefits for the purpose of calculating their Cash Equivalent Transfer Value and their single total figure of remuneration, as of 31 March 2023 and 31 March 2024, reflects the fact that membership between 1 April 2015 and 31 March 2022 has been rolled back into the PCSPS. Although members will in due course get an option to decide whether that period should count towards PCSPS or alpha benefits, the figures show the rolled back position i.e., PCSPS benefits for that period.

The partnership pension account is an occupational defined contribution pension arrangement which is part of the Legal & General Mastertrust. The employer makes a basic contribution of between 8% and 14.75% (depending on the age of the member). The employee does not have to contribute but, where they do make contributions, the employer will match these up to a limit of 3% of pensionable salary (in addition to the employer’s basic contribution). Employers also contribute a further 0.5% of pensionable salary to cover the cost of centrally provided risk benefit cover (death in service and ill health retirement).

Further details about pension arrangements are on the Civil Service Pension  Scheme website.

The cash equivalent transfer value

A Cash Equivalent Transfer Value (CETV) is the actuarially assessed capitalised value of the pension scheme benefits accrued by a member at a particular point in time.

The benefits valued are the member’s accrued benefits and any contingent spouse’s pension payable from the scheme. A CETV is a payment made by a pension scheme or arrangement to secure pension benefits in another pension scheme or arrangement when the member leaves a scheme and chooses to transfer the benefits accrued in their former scheme. The pension figures shown relate to the benefits that the individual has accrued as a consequence of their total membership of the pension scheme, not just their service in a senior capacity to which disclosure applies.

The figures include the value of any pension benefit in another scheme or arrangement which the member has transferred to the Civil Service pension arrangements. They also include any additional pension benefit accrued to the member as a result of their buying additional pension benefits at their own cost. CETVs are calculated in accordance with The Occupational Pension Schemes (Transfer Values) (Amendment) Regulations 2008 and do not take account of any actual or potential reduction to benefits resulting from Lifetime Allowance Tax which may be due when pension benefits are taken.

The real increase in the CETV

This reflects the increase in CETV that is funded by the employer. It does not include the increase in accrued pension due to inflation, contributions paid by the employee (including the value of any benefits transferred from another pension scheme or arrangement) and uses common market valuation factors for the start and end of the period.

Civil Service and other compensation schemes: exit packages (this information is subject to audit)

During 2023–24 no exit packages were paid (one in 2022–23 in the range £100,000 to £150,000).

Departure costs were approved by the Cabinet Office and were paid in accordance with the provisions of the Civil Service Compensation Scheme, a statutory scheme made under the Superannuation Act 1972. Exit costs are accounted for in full in the year of departure, there were no costs of this nature during 2023–24 (2022–23 £174,000). Where the public body has agreed early retirements, the additional costs are met by the public body and not by the Civil Service pension scheme. Ill-health retirement costs are met by the pension scheme and are not included in the table.

Tax arrangements of public sector appointees

In accordance with HM Treasury guidance on disclosure, the following tables set out the number of interim staff and the assurances given about tax status.

Highly paid off-payroll worker engagements as at 31 March 2024, earning £245 per day or greater.
No engagement met the above criteria

2022–23: there were no existing engagements as at 31 March 2023 which were over 6 months.

Highly paid off-payroll worker engagements as at 31 March 2024, earning £245 per day or greater.	Total
Number of off-payroll workers engaged during the year ended 31 March 2024	2
Of which:
Not subject to off-payroll legislation	–
Subject to off-payroll legislation and determined as in-scope of IR35	2
Subject to off-payroll legislation and determined as out-of- scope of IR35	–
Engagements reassessed for compliance or assurance purposes	–
Engagements that saw a change to IR35 status following review	–

Between 1 April 2022 and 31 March 2023 the number of engagements, that met the above criteria was 10.

Off-payroll engagements of Board members or senior officials with significant financial responsibility, between 1 April 2023 and 31 March 2024	Total
Number of off-payroll engagements of Board members or senior officials with significant financial responsibility, during the financial year	0
Total number of individuals on payroll and off-payroll who have been deemed ‘Board members or senior officials with significant financial responsibility’, during the financial year. This figure includes both payroll and off-payroll engagements.	17

2022–23: there were no off-payroll board members, the total number of Board members was 21.

Staff report

Staff numbers and related cost (average staff numbers and staff costs are subject to audit).

Staff numbers

The number of staff we employed on 31 March 2024 is as follows:

2023–2024

Category	Female	Male	Total
Directors (SCS Grade 1–3 equivalent)	4	5	9
Other employees	128	65	193
Other employees (short-term workers)	10	1	11
Other employees (seconded/loans inwards)	–	3	3
Total	142	74	216
Interims and support workers	1	–	1
Other employees (seconded/loans outwards)	2	–	2

At 31 March 2024, 216 individuals were directly employed by EHRC on a permanent or fixed-term basis (compared with 228 on 31 March 2023). No interim staff were engaged on 31 March 2024. Three employees were seconded to the EHRC from other government departments and two were seconded or loaned out on 31 March 2024.

The average number of FTE employees in post during the year is detailed in the following table.

Category	2023–2024	2022–2023
Permanently employed staff	195	182
Other	-	-
Short-term contract staff	13	21
Inward secondments	3	5
Agency staff (contracted staff)	1	5
Total	212	213

The average number of FTE employees engaged during the year 2023–24 was 212 (213 in 2022–23), including seconded, loan or agency staff.

Staff costs

Category	2023–2024 Permanently employed staff £000	2023-2024 Others (agency and FTC) £000	2023–2024 Total £000	2022–2023 Total £000
Wages and salaries	10,271	285	10,556	9,578
Social security costs	1,134	33	1,167	1,103
Apprenticeship levy	39	–	39	35
Pension costs	2,749	77	2,826	2,632
Inward secondments	–	40	40	158
Untaken annual leave[footnote 19]	(22)	–	(22)	34
Exit costs	–	–	–	135
Total staff costs	14,171	435	14,606	13,675
Recoveries in respect of (outward) secondments[footnote 20]	(169)	–	(169)	(115)
Total staff costs (net of amounts recovered)	14,002	435	14,437	13,560
Interim costs	–	43	43	373
Total	14,002	478	14,480	13,933

Sickness absence

The sickness absence rate for staff increased compared to 2022–23 and is shown in the table below as average working days lost (AWDL) per person. Increases in days lost to sickness absence are mostly due to a small number of long-term absences that are discrete and well managed, and an increase in short term absence due to winter viruses. All other absence is in line with previous years trends.

Date range	AWDL
2023–24 (as at 31 March 24)	7.9
2022–23 (as at 31 March 23)	6.0

Staff turnover

During 2023–24, employee turnover continued to stabilise and remained consistently below the previous year’s level. Our rolling annual turnover of permanent staff was 13.8% on 31 March 2024, a reduction from 16.5% on 31 March 2023. We offer confidential exit interviews to leavers to gain insight into how we can improve our working environment, culture and relationships.

Employee engagement

We are committed to fostering a culture of open communication, transparency and continuous improvement at the EHRC. So that we can best understand the experiences of all our people, rather than repeating our annual people survey in 2023–24, we instead ran regular pulse surveys and held a series of informal in person focus groups between our senior leaders and colleagues.

Through these sessions, every member of staff had the opportunity to engage directly with our Chief Executive and Deputy Chief Executive, raise any concerns, express their opinions on topics important to them, and gain insights into the EHRC’s role, remit, challenges, and opportunities. This approach allowed for rich dialogue and deeper connections between our leadership team and staff members. The insights gained from these sessions have been invaluable in informing our understanding of how colleagues are feeling and areas for improvement. Some of the key themes we heard were around pay and reward, budget planning, dispersed teams and our ways of working. We will spend next year and beyond working collaboratively to make improvements where needed.

During 2024–25 we will return to conducting a full people survey to ensure we continue to capture both quantitative and qualitative feedback on a range of topics from our workforce.

We also have a Staff Forum that typically meets every two months. This provides a dedicated space for colleagues across the Commission to engage with and feed back on matters affecting the wider workforce.

Recruitment practices

Our recruitment activity reduced during 2023–24 due to a reduction in leavers and proactive steps taken to ensure the affordability and effectiveness of our workforce.

We continued to review and improve our processes and practices, including our induction and onboarding process. Our end-to-end workforce planning, recruitment and onboarding processes were reviewed by internal audit during the year and received ‘reasonable assurance’, which means that our human resource management processes and procedures are robust and applied consistently.

We continued to reduce our use of agency workers, with only two short term engagements during the year.

Facility time

The Trade Union (Facility Time Publication Requirements) Regulations 2017 came into force on 1 April 2017 and requires relevant public sector employers, to ‘collate and publish, on an annual basis, a range of data on the amount and cost of facility time within their organisation’.

Facility time is defined in the regulations as ‘the provision of paid or unpaid time from an employee’s normal role to undertake Trade Union duties and activities as a Trade Union representative’. The tables below show the amount and cost of facility time for 2023–24.

Relevant union officials	2023–24
Number of employees who were relevant union representatives during the relevant period	22
FTE employee number	19.29

Percentage of time spent on facility time	0	1 – 50	51 – 99	100
Number of employees	4	18	0	0

Percentage of pay bill spent on facility time	Figure
Total cost of facility time £000	10
Total pay bill (staff) £000	14,437
%	0.07

The regulations require organisations to publish how many hours were spent by trade union officials on paid trade union activities as a percentage of total paid facility time hours. Facility time is paid or unpaid time that trade union officials receive from their normal role to undertake trade union duties and activities.

Paid trade union duties include, for example, preparing for negotiation or consultation and attending meetings; accompanying their trade union members to meetings; and completing training relevant to their trade union role.

Paid trade union activities are defined as the time taken off with pay by trade union officials to carry out matters beyond the immediate interest or concern of EHRC. These activities include attendance at national executive committee meetings and attendance at trade union conferences.

Paid trade union activities	%
Time spent on paid trade union activities as a percentage of total paid facility time hours	33.48

Expenditure on consultancy

Consultancy spend during 2023–24 totalled £22,900 and related to independent reviews into our governance arrangements. This was nil in 2022–23.

People policies

A comprehensive set of policies and procedures are in place to support colleagues during their time at work. During 2023–24, we commenced a full review of our workplace policies and procedures and this work will continue into 2024–25.

All our workplace policies and procedures are designed to be inclusive for everyone working at the EHRC, supporting reasonable adjustments, flexible working, and our inclusive culture.

We are a Disability Confident Leader and operate a guaranteed interview scheme for applicants who meet the minimum criteria with requested reasonable adjustments made at all stages of the process and we use recruitment software to anonymise applications to ensure fairness.

We report on policy compliance and review on an annual basis to the ARAC (Audit and Risk Assurance Committee) and People and Workspaces Committee. An organisational policy register goes to both these groups annually.

We recognise and work with the Public and Commercial Services (PCS) and Unite trade unions and we operate a formal Health and Safety Committee to which both management and trade union representatives are invited.

Diversity and inclusion

We promote equality, diversity and inclusion for all and are pleased to have maintained our high representation across all protected characteristics this year. We encourage staff to declare these characteristics to ensure we have an accurate picture of our workforce.

In 2023–24 we continued to work with our staff networks and with our Staff Forum, to further improve our employee experience. Through the People and Workspace Committee we are reviewing our diversity and inclusion work.

We set up an accessibility working group to ensure that our digital content is inclusive for everyone working at the EHRC, and we offered all our people Microsoft accessibility training.

We continued to engage with the Civil Service Fast Stream internship programme. In 2023–24, we hosted three individuals on an 8 week internship and two interns from the Autism Exchange programme, providing valuable work experience to a diverse group.

Health and wellbeing

Supporting our people with their wellbeing at work is a priority for us. In 2023–24, we offered all colleagues who were not eligible through the NHS, an influenza vaccination, we continued to provide colleagues with access to a fully comprehensive employee assistance programme, and valued support from our internal Mental Health Supporters and Wellbeing staff network.

Like other employers, the menopause is a health and wellbeing concern for our staff. In 2023–24, we introduced a new menopause in the workplace policy and supported its implementation with e-learning, videos, blogs from senior leaders and a new Menopause Cafe allowing those who are experiencing the menopause or supporting others to share their experiences. We also began providing free access to period products in all our office locations.

All staff have access to a range of learning and development resources and agree personal development objectives with their line managers. In 2023–24, we commenced a leadership development series, with the aim of improving leadership across the EHRC and strengthening our diverse talent pipeline for senior roles. In 2024–25, we will invest

in an Aspiring Managers Programme for colleagues wanting to progress their careers into a managerial role, and a management development series for our existing managers to further strengthen our management capabilities.

Pensions

The PCSPS is an unfunded multi-employer defined benefit scheme in which the EHRC is unable to identify its share of the underlying assets and liabilities. A full actuarial valuation was carried out as at 31 March 2020. Details can be found in the resource accounts of the Cabinet Office: Civil Superannuation.

In 2023–24, employers’ contributions of £2,810,565 were payable to the PCSPS (2022– 23: £2,626,483) at one of four rates in the range 26.6% to 30.3% (2022–23: 26.6%–30.3%) of pensionable pay, based on salary bands. The scheme actuary reviews employer contributions every four years following a full scheme valuation. The salary bands

and contribution rates were revised for 1 April 2019 – 31 March 2024 and remained unchanged until 2024–25. The contribution rates reflect benefits as they are accrued, not when the costs are actually incurred, and reflect past experience of the scheme. Contributions due to the PCSPS at the reporting period date were £274,191.

Employees can opt to open a partnership pension account, a stakeholder pension with an employer contribution. Employers’ contributions of £14,990 (2022–23 £6,102) were paid to an appointed stakeholder pension provider. Employer contributions are age-related and range from 8.0 to 14.75 per cent (2022–23: 8.0 to 14.75 per cent) of pensionable pay. Employers also match employee contributions up to 3 per cent of pensionable pay. In addition, employer contributions of £587; 0.5 per cent (2022–23: £218; 0.5 per cent)

of pensionable pay, were payable to the PCSPS to cover the cost of the future provision of lump sum benefits on death in service and ill health retirement of these employees. Contributions due to the partnership pension providers at the reporting period date were £4,183. Contributions prepaid at that date were nil.

There were no early retirements on ill-health grounds (none in 2022–23).

Parliamentary accountability and audit report

This section summarises the key parliamentary accountability statements within the annual report and accounts and contains the certificate and report of the Comptroller and Auditor General.

Parliamentary disclosures – all disclosures are subject to audit

Losses and special payments

‘Managing Public Money’ and the Financial Reporting Manual (FReM) require a statement showing losses and special payments by value and by type to be shown separately where they exceed £300,000 in total, and those individually that exceed £300,000.

There were no losses or special payments in 2023–24 that require disclosure in the Annual Report and Accounts (none in 2022–23).

Remote contingent liabilities

A remote contingent liability exists where the likelihood of settlement is too remote to meet the definition of a contingent liability.

There are no remote contingent liabilities as at 31 March 2024 (none at 31 March 2023).

Fees and charges

EHRC does not have the power to raise income through the levy of fees or charges.

Regularity of expenditure

The Accounting Officer is able to identify any material irregular or improper use of funds. To the date of this statement, there have been no instances of irregularity, impropriety or non-compliance discovered during the financial year.

John Kirkpatrick

Chief Executive and Accounting Officer

10 September 2024

Certificate and Report of the Comptroller and Auditor General to the Houses of Parliament

Opinion on financial statements

I certify that I have audited the financial statements of the Commission for Equality and Human Rights (trading as the Equality and Human Rights Commission) for the year ended 31 March 2024 under the Equality Act 2006.

The financial statements comprise the Commission’s

• Statement of Financial Position as at 31 March 2024;
• Statement of Comprehensive Net Expenditure, Statement of Cash Flows and Statement of Changes in Taxpayers’ Equity for the year then ended; and
• the related notes including the significant accounting policies.

The financial reporting framework that has been applied in the preparation of the financial statements is applicable law and UK-adopted International Accounting Standards.

In my opinion, the financial statements:

• give a true and fair view of the state of the Commission’s affairs as at 31 March 2024 and its net expenditure for the year then ended; and
• have been properly prepared in accordance with the Equality Act 2006 and Secretary of State directions issued thereunder.

Opinion on regularity

In my opinion, in all material respects, the income and expenditure recorded in the financial statements have been applied to the purposes intended by Parliament and the financial transactions recorded in the financial statements conform to the authorities which govern them.

Basis for opinions

I conducted my audit in accordance with International Standards on Auditing (UK) (ISAs UK), applicable law and Practice Note 10 Audit of Financial Statements and Regularity of Public Sector Bodies in the United Kingdom (2022). My responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements section of my certificate.

Those standards require me and my staff to comply with the Financial Reporting Council’s Revised Ethical Standard 2019. I am independent of the Commission in accordance with the ethical requirements that are relevant to my audit of the financial statements in the UK. My staff and I have fulfilled our other ethical responsibilities in accordance with these requirements.

I believe that the audit evidence I have obtained is sufficient and appropriate to provide a basis for my opinion.

Conclusions relating to going concern

In auditing the financial statements, I have concluded that the Commission’s use of the going concern basis of accounting in the preparation of the financial statements is appropriate.

Based on the work I have performed, I have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the Commission’s ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.

My responsibilities and the responsibilities of the Accounting Officer with respect to going concern are described in the relevant sections of this certificate.

The going concern basis of accounting for the Commission is adopted in consideration of the requirements set out in HM Treasury’s Government Financial Reporting Manual, which requires entities to adopt the going concern basis of accounting in the preparation of the financial statements where it is anticipated that the services which they provide will continue into the future.

Other Information

The other information comprises information included in the Annual Report, but does not include the financial statements and my auditor’s certificate and report thereon. The Accounting Officer is responsible for the other information.

My opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in my certificate, I do not express any form of assurance conclusion thereon.

My responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or my knowledge obtained in the audit, or otherwise appears to be materially misstated.

If I identify such material inconsistencies or apparent material misstatements, I am required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work I have performed, I conclude that there is a material misstatement of this other information, I am required to report that fact. I have nothing to report in this regard.

Opinion on other matters

In my opinion the part of the Remuneration and Staff Report to be audited has been properly prepared in accordance with Secretary of State directions issued under the Equality Act 2006.

In my opinion, based on the work undertaken in the course of the audit:

• the parts of the Accountability Report subject to audit have been properly prepared in accordance with Secretary of State directions made under the Equality Act 2006; and
• the information given in the Performance Report and the Accountability Report for the financial year for which the financial statements are prepared is consistent with the financial statements and is in accordance with the applicable legal requirements.

Matters on which I report by exception

In the light of the knowledge and understanding of the Commission and its environment obtained in the course of the audit, I have not identified material misstatements in the Performance Report and the Accountability Report.

I have nothing to report in respect of the following matters which I report to you if, in my opinion:

• adequate accounting records have not been kept by the Commission or returns adequate for my audit have not been received from branches not visited by

my staff; or

• I have not received all of the information and explanations I require for my audit; or
• the financial statements and the parts of the Accountability Report subject to audit are not in agreement with the accounting records and returns; or
• certain disclosures of remuneration specified by HM Treasury’s Government Financial Reporting Manual have not been made or parts of the Remuneration and Staff Report to be audited is not in agreement with the accounting records and returns; or
• the Governance Statement does not reflect compliance with HM Treasury’s guidance.

Responsibilities of the Commission and Accounting Officer for the financial statements

As explained more fully in the Statement of Accounting Officer’s Responsibilities, the Commission and Accounting Officer are responsible for:

• maintaining proper accounting records;
• providing the C&AG with access to all information of which management is aware that is relevant to the preparation of the financial statements such as records, documentation and other matters;
• providing the C&AG with additional information and explanations needed for his audit;
• providing the C&AG with unrestricted access to persons within the Commission from whom the auditor determines it necessary to obtain audit evidence;
• ensuring such internal controls are in place as deemed necessary to enable the preparation of financial statements to be free from material misstatement, whether due to fraud or error;
• preparing financial statements which give a true and fair view in accordance with Secretary of State directions issued under the Equality Act 2006;
• preparing the annual report, which includes the Remuneration and Staff Report, in accordance with Secretary of State directions issued under the Equality Act 2006; and
• assessing the Commission’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Accounting Officer anticipates that the services provided by the Commission will not continue to be provided in the future.

Auditor’s responsibilities for the audit of the financial statements

My responsibility is to audit, certify and report on the financial statements in accordance with the Equality Act 2006.

My objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue a certificate that includes my opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

Extent to which the audit was considered capable of detecting non- compliance with laws and regulations including fraud

I design procedures in line with my responsibilities, outlined above, to detect material misstatements in respect of non-compliance with laws and regulations, including fraud. The extent to which my procedures are capable of detecting non-compliance with laws and regulations, including fraud is detailed below.

Identifying and assessing potential risks related to non-compliance with laws and regulations, including fraud

In identifying and assessing risks of material misstatement in respect of non-compliance with laws and regulations, including fraud, I:

• considered the nature of the sector, control environment and operational performance including the design of the Commission’s accounting policies.
• inquired of management, the Commission’s head of internal audit and those charged with governance, including obtaining and reviewing supporting documentation relating to the Commission’s policies and procedures on:
  • identifying, evaluating and complying with laws and regulations;
  • detecting and responding to the risks of fraud; and
  • the internal controls established to mitigate risks related to fraud or non- compliance with laws and regulations including the Commission’s controls relating to the Commission’s compliance with the Equality Act 2006 and Managing Public Money;
• inquired of management, the Commission’s head of internal audit and those charged with governance whether:
  • they were aware of any instances of non-compliance with laws and regulations;
  • they had knowledge of any actual, suspected, or alleged fraud;
• discussed with the engagement team and the relevant external specialists, including pensions expertise regarding how and where fraud might occur in the financial statements and any potential indicators of fraud.

As a result of these procedures, I considered the opportunities and incentives that may exist within the Commission for fraud and identified the greatest potential for fraud in the following areas: revenue recognition, posting of unusual journals, complex transactions and bias in management estimates. In common with all audits under ISAs (UK), I am required to perform specific procedures to respond to the risk of management override.

I obtained an understanding of the Commission’s framework of authority and other legal and regulatory frameworks in which the Commission operates. I focused on those laws and regulations that had a direct effect on material amounts and disclosures in the financial statements or that had a fundamental effect on the operations of the Commission. The key laws and regulations I considered in this context included Equality Act 2006, Managing Public Money, employment law, pensions legislation and tax Legislation.

I considered other risk assessment procedures performed relating to fraud, non- compliance with laws and regulations and regularity including review of Commissioner meeting minutes; attending the Audit and Risk Assurance Committee; enquiries of management, internal audit and those charged with governance; review of significant and unusual transactions; and review of segregation of duties and mitigating controls.

Audit response to identified risk

To respond to the identified risks resulting from the above procedures:

• I reviewed the financial statement disclosures and testing to supporting documentation to assess compliance with provisions of relevant laws and regulations described above as having direct effect on the financial statements;
• I enquired of management, the Audit Risk Assurance Committee and in-house legal counsel concerning actual and potential litigation and claims;
• I reviewed minutes of meetings of those charged with governance and the Board and internal audit reports; and

in addressing the risk of fraud through management override of controls, I tested the appropriateness of journal entries and other adjustments; assessed whether the judgements on estimates are indicative of a potential bias; and evaluated the business rationale of any significant transactions that are unusual or outside the normal course of business. I communicated relevant identified laws and regulations and potential risks of fraud to all engagement team members and remained alert to any indications of fraud or non-compliance with laws and regulations throughout the audit.

A further description of my responsibilities for the audit of the financial statements is located on the Financial Reporting Council’s website. This description forms part of my certificate.

Other auditor’s responsibilities

I am required to obtain sufficient appropriate audit evidence to give reasonable assurance that the expenditure and income recorded in the financial statements have been applied to the purposes intended by Parliament and the financial transactions recorded in the financial statements conform to the authorities which govern them.

I communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control I identify during my audit.

Report

I have no observations to make on these financial statements.

Gareth Davies

Comptroller and Auditor General

10 September 2024

National Audit Office
157–197 Buckingham Palace Road
Victoria
London
SW1W 9SP

Statement of accounts: 1 April 2023 – 31 March 2024

These accounts are presented to Parliament pursuant to paragraph 40 of Schedule 1 to the Equality Act 2006.

EHRC is a statutory non-departmental public body established under the Equality Act 2006. Its powers and duties are described in the 2006 and 2010 Equality Acts.

These accounts are prepared in accordance with the Government Financial Reporting Manual (FReM) and International Financial Reporting Standards (IFRS).

Primary statements

The Primary Statements include the Statement of Comprehensive Net Expenditure, the Statement of Financial position (Balance Sheet), the Cash Flow Statement and the Statement of Changes in Taxpayer’s Equity. The Primary Statements are complemented by the subsequent notes.

The Statement of Comprehensive Net Expenditure shows the cost for the year of the EHRC’s activities, it essentially captures the inflow and outflow of resources for the financial year up to 31 March 2024, which have been received or incurred as part of the ordinary activities of the EHRC.

The Statement of Financial Position (Balance Sheet) is a statement showing the EHRC’s assets and liabilities: that is, what is owned and what is owed on 31 March 2024. The net impact of this is funded by taxpayers’ equity which is received as Grant in Aid funding from our sponsor body.

The Cash Flow Statement shows the changes in cash during the financial year and cash balance at the 31 March 2024. Investing activities represent the extent to which cash outflows have been made for resources which are intended to contribute to the EHRC’s infrastructure.

Statement of Comprehensive Net Expenditure (SoCNE)

for the year ended 31 March 2024

Category	Notes	2023–2024 £000	2022–2023 £000
Income	-	-	-
Operating income	4	(28)	(125)
Total operating income		(28)	(125)
Expenditure	-	-	-
Staff costs	3	14,480	13,933
Board and Committee Fees and NIC’s	3	208	223
Purchase of goods and services	3	3,032	3,455
Depreciation and impairment charges	3	916	912
Provision expense	3	103	(169)
Total operating expenditure		18,739	18,354
Net operating expenditure		18,711	18,229
Interest cost on pension scheme liabilities	12	44	21
Interest cost on leases (IFRS16)	13	12	15
Net expenditure for the year		18,767	18,265
Other comprehensive net expenditure	-	-	-
Items which will not be classified to net operating costs:
net (gain)/loss on revaluation of property, plant and equipment	5	(16)	(34)
net (gain)/loss on revaluation of intangible assets	6	–	(2)
actuarial loss/(gain) on pension scheme liabilities	12	111	(211)
Comprehensive net expenditure for the year		18,862	18,018

The notes on pages 133 to 165 form part of these accounts.

Statement of Financial Position (SoFP)

as at 31 March 2024

Category	Notes 2023–2024	2023–2024 £000	2022–2023 £000
Non-current assets	-	-	-
Property, plant and equipment	5	937	1,098
Intangible assets	6	5	65
Right of use assets	13	905	1,343
Trade and other receivables	9	54	85
Total non-current assets		1,901	2,591
Current assets	-	-	-
Trade and other receivables	9	587	596
Cash and cash equivalents	8	244	32
Total current assets		831	628
Total assets		2,732	3,219
Current liabilities	-	-	-
Trade and other payables	10	(1,297)	(1,591)
Lease liabilities	13	(258)	(447)
Dilapidations provision	11	(37)	–
Pension liabilities	12	(118)	(116)
Total current liabilities		(1,710)	(2,154)
Total assets less current liabilities		1,022	1,065
Non-current liabilities	-	-	-
Lease liabilities	13	(599)	(857)
Dilapidations provision	11	(282)	(216)
Pension liabilities	12	(1,048)	(1,010)
Total non-current liabilities		(1,929)	(2,083)
Total assets less total liabilities		(907)	(1,018)
Taxpayers’ equity	-	-	-
Revaluation reserve	SoCiTE	52	57
General reserve	SoCiTE	(959)	(1,075)
Total equity		(907)	(1,018)

The notes on pages 133 to 165 form part of these accounts.

John Kirkpatrick

Chief Executive and Accounting Officer

10 September 2024

Statement of Cash Flows (SoCF)

for the year ended 31 March 2024

Category	Notes 2023–2024	2023–2024 £000	2022–2023 £000
Cash flows from operating activities	-	-	-
Net expenditure	SoCNE	(18,767)	(18,265)
Adjustments for non-cash transactions	SoCNE	916	912
Decrease/(increase) in trade and other receivables	9	40	39
(Decrease)/increase in trade and other payables	10	(294)	(424)
Increase/(decrease)/in provisions	11	103	(216)
Pension payments	12	(115)	(105)
Lease movements not passing through the SoCNE		3	(86)
Movement in capital payables not passing through the SoCNE		79	152
Interest expense	SoCNE	56	36
Net cash outflow from operating activities (a)		(17,979)	(17,957)
Cash flows from investing activities	-	-	-
Purchase of property, plant and equipment (PPE) and intangible assets	5&6	(244)	(493)
Movement in capital payables		(79)	(152)
Net cash outflow from investing activities (b)		(323)	(645)
Cash flows from financing activities	-	-	-
Grant-in-aid received from sponsoring department	SoCiTE	18,973	18,661
Payments in respect of lease liabilities	13	(447)	(387)
Interest expense in respect of lease liabilities	13	(12)	(15)
Net Financing (c)		18,514	18,259
Net increase/(decrease) in cash and cash equivalents in the year (a+b+c)	8	212	(343)
Cash and cash equivalents at the beginning of the financial year	8	32	375
Cash and cash equivalents at the end of the period	8	244	32

The notes on pages 133 to 165 form part of these accounts.

Statement of Changes in Taxpayers’ Equity (SoCiTE)

for the year ended 31 March 2024

Category	Revaluation reserve Notes	Revaluation reserve £000	General reserve £000	Total £000
Balance at 31 March 2022		51	(1,712)	(1,661)
Grant-in-aid received from sponsoring department – cash draw down	SoCF	–	18,661	18,661
Net expenditure for the year	SoCNE	–	(18,265)	(18,265)
Remeasurements – actuarial loss / (gain)on pension scheme liabilities	12	–	211	211
Revaluation of PPE and intangibles	5&6	36	–	36
Transfer between reserves		(30)	30	–
Balance at 31 March 2023		57	(1,075)	(1,018)
Grant-in-aid received from sponsoring department – cash draw down	SoCF	–	18,973	18,973
Net expenditure for the year	SoCNE	–	(18,767)	(18,767)
Remeasurements – actuarial (gain) / loss on pension scheme liabilities	12	–	(111)	(111)
Revaluation of PPE and intangibles	5&6	16	–	16
Transfer between reserves		(21)	21	–
Balance at 31 March 2024		52	(959)	(907)

The notes on pages 133 to 165 form part of these accounts.

Notes to the financial statements for the period ending 31 March

1.0 Accounting policies

The EHRC is a statutory non-departmental public body sponsored by the UK government’s Minister for Women and Equalities established by the Equality Act 2006. It operates independently from government and Parliament and is Britain’s national equality body.

These financial statements have been prepared in a form consistent with the Accounts Direction issued by the Secretary of State in accordance with the Equality Act 2006, and in accordance with the Government Financial Reporting Manual (FReM) as issued by HM Treasury. The accounting policies described in the FReM apply International Financial Reporting Standards (IFRS) as adapted or interpreted for the public sector. Where the FReM permits a choice of accounting policy, we have selected the accounting policy judged to be most appropriate to the circumstances of our organisation for the purpose of giving a true and fair view. The policies we have adopted are described below. They have been applied consistently in dealing with items that are considered material to the accounts.

There have been no changes to the underlying accounting policies used to prepare the 2023–24 Statement of Accounts.

Policies will continue to be reviewed as part of the accounts preparation and may be re-worded where this will aid understanding.

Figures in the financial statements are rounded to the nearest £000 unless otherwise stated.

We operate across the three nations of Great Britain and have offices in:

• London – Suite 3.04, Tintagel House, 92 Albert Embankment, London SE1 7TY
• Manchester – Arndale House, Arndale Centre, M4 3AQ
• Cardiff – Companies House (1st Floor), Crown Way, Cardiff, CF14 3UZ, and
• Glasgow – 4th Floor, 140 West George Street, Glasgow, G2 2HG

1.1 Accounting convention

These financial statements have been prepared under the historical cost convention modified to account for the revaluation of property, plant and equipment and intangible assets where material.

1.2 Going concern

The financial statements have been prepared on a going-concern basis. This is based on the assessment that the EHRC will continue to receive funding and operations will continue for the foreseeable future. This assessment has also considered that, for non- trading public sector entities like the EHRC, the FReM provides that ‘the anticipated continuation of the provision of a service in the future, as evidenced by inclusion of financial provision for that service in published documents, is normally sufficient evidence of going concern.’

The Equality Act 2006 requires the Secretary of State to provide sufficient funding for the EHRC to carry out the statutory duties contained within the Act and as an arms length body sponsored by the Cabinet Office, the EHRC has no reason to assume that future funding will not be forthcoming. This going concern assessment is made up to 12 months from signing date which includes the initial part of the 2025–26 financial year. The EHRC has assumed that funding will continue beyond the 2024–25 financial year as outlined in the requirement to submit a three-year spending plan.

The Framework agreement between the EHRC and the Cabinet Office provides assurance that in the event of the EHRC being wound up and assets or liabilities of the EHRC will be passed to any successor organisation or the Cabinet Office if there is no successor body.

In conclusion, these factors, and the anticipated future provision of services in the public sector, support the EHRC’s adoption of the going concern basis for the preparation of the accounts.

1.3 Accounting judgements and key sources of estimation uncertainty

In applying the accounting policies and preparing the financial statements management is required to make certain judgements regarding complex transactions or those involving uncertainty about future events and estimates and assumptions about the carrying amounts of assets and liabilities that are not readily apparent from other sources. The estimates and associated assumptions are based on historical experience and other factors considered to be relevant. These estimates and underlying assumptions are continually reviewed.

The nature of estimation, however, means that actual outcomes could differ from those estimates and could cause adjustment to the carrying amounts of assets and liabilities within the next financial year.

Areas of estimation uncertainty

The following are the key assumptions concerning the future and other key sources of estimation uncertainty at the time of the statement of our financial position:

• Useful lives of non-current assets: these are reviewed as at the reporting date and updated if expectations differ from previous estimates due to physical wear and tear, technical or commercial obsolescence, legal or other limits on their use
• Impairment of non-current assets
• Leases (right of use assets) break clauses: where a lease contains a break clause management assess whether or not this is likely to be exercised at commencement of the lease and the life of the asset will recognise this date. These will be reviewed to assess whether or not any changes to circumstances will result in changes to the lease term
• Leases (right of use assets) discount rates: If a discount rate is not implicit in a lease, the rate promulgated by HM Treasury effective at the date of the initial recognition or remeasurement will be used
• Provisions: Provisions are based on the best estimate of the amount required to settle an obligation following an assessment of risks and uncertainties, HM Treasury discount rates for general provisions and post-employment benefits are applied where appropriate and may have an effect on liabilities disclosed
• Retirement benefit obligations: The pension scheme for the former chair of the EHRC, and for the former chairs and deputy chairs of legacy commissions, is unfunded and exposes the EHRC to uncertainty arising from the actuarial valuation of the scheme, which uses factors such as changes in life expectancy and discount rates to calculate the scheme’s total liability.

1.4 Newly issued IFRS not yet effective

New or amended standards are implemented in line with their adoption by the FReM.

IFRS17 Insurance contracts replaces IFRS 4 Insurance contracts and is expected to become effective for public sector bodies from 1 April 2025.

Our assessment is that this will have no impact on our financial statements because we do not enter into insurance contracts.

There are no other IFRS interpretations not yet effective that would be expected to have material impact on the EHRC financial statements. No standards have been adopted early.

1.5 Grant-in-aid

The FReM requires the EHRC to account for grant-in-aid received as financing and to credit this to taxpayers’ equity. This is due to grant-in-aid being regarded as a contribution from a controlling party, which gives rise to a financial interest in the residual interest of the EHRC.

Grant-in-aid received for purchasing non-current assets is also credited to taxpayers’ equity.

1.6 Employee benefits

Benefits payable during employment

IAS19: Employee benefits, prescribes rules for recognition and presentation of various types of benefits that employers provide to their employees, under which short-term benefits are recognised as an undiscounted expense in the accounting period and include:

• staff salary costs which are recorded as an expense as soon as an organisation is obliged to pay them
• performance payments unpaid at the end of the year are recognised on an accruals basis, calculated as a fixed proportion of the total pay bill, which represents the maximum amount that can be paid out.

Employee leave accrual

An accrual is made for the cost of any staff annual leave entitlement not taken at 31 March 2024, the accrual is made at the salary rates applicable on the date the accrual is made.

1.7 Operating segments

Operating segments (note 2) are based on the main reporting areas of our organisation (Networks) and align with our internal reporting. Since segmental information for assets and liabilities is not reported to the Chief Operating Decision-Maker (CODM) at a segmental level, these are not included in the segmental reporting analysis.

The CODM has been identified as the Accounting Officer.

1.8 Recognition of income and expenditure

Income and Expenditure is accounted for in the year in which it takes place and is recognised in the financial statements on an accruals basis.

Expenditure in relation to services received (including services provided by employees) is recognised at the point that the services are received rather than when payments are made.

Operating income is principally the recovery (either full or partial) of costs incurred from other parties. Income is recognised when the transaction can be reliably measured, and it is probable that economic benefits associated with the transaction will flow to the EHRC.

Where income and expenditure has been recognised but cash has not been received or paid, a receivable or payable for the relevant amount is recorded in our statement of financial position.

1.9 Prepayments

Prepayments for goods and services which are to be provided in future periods are recorded as assets in our statement of financial position and recognised as an expense either when the goods or service are received or over the life of the agreement.

Items are recognised for prepayment if the total cost exceeds £100, items include:

• where a contractual obligation exists to pay for goods or services in advance of consumption (for example building lease charges) the cost is expensed over the period of the charge
• licence costs, subscriptions and maintenance agreements which are paid in full in advance are expensed across the duration of the agreement.

1.10 Property, plant and equipment

Recognition

Expenditure on the acquisition, creation or enhancement of property, plant and equipment is capitalised on an accruals basis, provided that a future economic benefit can be recognised, where the expected useful lives of the assets exceeds one year and that the cost of the item can be measured reliably.

Expenditure that maintains but does not add to an asset’s potential to deliver future economic benefits or service potential (for example, for repairs and maintenance) is charged as an expense when it is incurred.

A £3,000 de minimis limit for capital expenditure is applied, either individually or in related groups of similar assets.

All property, plant and equipment are measured initially at cost, representing the cost attributable to acquiring the asset and bringing it into use in the manner intended by management. Assets that are held for their service potential and are not in use are measured subsequently at their current value in existing use.

All assets are restated at current value each year using producer price indices published by the Office for National Statistics, which are deemed to be the most appropriate valuation methodology available. Any gain on revaluation is credited to the revaluation reserve. Any loss is debited to the revaluation reserve to the extent that a gain has previously been recorded, and otherwise to the statement of comprehensive net expenditure.

Depreciation

Property, plant and equipment are depreciated over their estimated useful economic life using the straight-line basis commencing when the asset is placed in service. All assets’ residual values, useful lives and methods of depreciation are reviewed at each financial reporting year-end and adjusted if appropriate.

We estimate the useful economic lives of assets as follows:

• fit-out costs (leasehold improvements) for premises: the lower of the useful economic life of the fit-out costs and the life of the lease
• office furniture: 10–15 years
• computer and networking equipment, telephones hardware: 2–7 years
• right of use assets: the contractual length of the lease, or where it is established that a break clause is likely to be exercised, the period of the break clause (see note 1.15)

Impairment

International Accounting Standard (IAS) 36, Impairment of Assets, has been adapted in the FReM.

Impairments that are due to a clear consumption of economic benefit are recognised in the statement of comprehensive net expenditure, rather than set against an available revaluation reserve.

Where impairment losses are identified that are not due to consumption, they are accounted for as follows:

• where there is a balance of revaluation gains for the asset in the Revaluation Reserve, the carrying amount of the asset is written down against that balance (up to the amount of the accumulated gains)
• where there is no balance in the Revaluation Reserve or an insufficient balance, the carrying amount of the asset is charged to the statement of comprehensive net expenditure

Where asset revaluations cause impairment, an assessment is carried out to determine whether the impairment is due to the consumption of economic benefit and should be recognised in the statement of comprehensive net expenditure.

Disposals

When an asset is disposed of or decommissioned, the carrying amount of the asset is charged to the statement of comprehensive net expenditure as a loss on disposal. Net gains from disposals are credited to the statement of comprehensive net expenditure (that is, netted off against the carrying value of the asset at the time of disposal).

1.11 Intangible assets

Recognition

Intangible assets are acquired computer software licences and costs incurred in the development phase of internal computer software projects.

Intangible assets are recognised at cost initially, assets are revalued annually using producer price indices published by the Office for National Statistics, which is deemed to be the most appropriate valuation methodology. Any gain on revaluation is credited to the revaluation reserve. Any loss is debited to the revaluation reserve to the extent that a gain has been recorded previously, and otherwise to the statement of comprehensive net expenditure.

Costs incurred in the developmental phase of internal software projects are only capitalised if they are associated directly with the production of identifiable computer software programs controlled by our organisation that would generate economic benefits beyond one year and provided that several criteria are satisfied. These include the technical feasibility of completing the asset so that it is available for use, the availability of adequate resources to complete the development and use the asset, and how the asset will generate future economic benefit.

Other costs associated with developing or maintaining computer software programmes are recognised as an expense when incurred.

Amortisation

Intangible assets are amortised over the estimated useful economic life of the asset using the straight-line basis, commencing at the point the asset is placed in service. Assets are assessed on an individual basis and an appropriate life applied dependent on the characteristics of the asset according to the following:

• software and associated services are assessed over the term of the software licence
• information technology assets are assessed over five years or over the unexpired time of the software licence (whichever is shorter)

Impairment

International Accounting Standard (IAS) 36, Impairment of Assets, has been adapted in the FReM.

Impairments that are due to a clear consumption of economic benefit should be recognised in the statement of comprehensive net expenditure, rather than set against an available revaluation reserve.

Where impairment losses not due to consumption are identified, they are accounted for as follows:

• where there is a balance of revaluation gains for the asset in the Revaluation Reserve, the carrying amount of the asset is written down against that balance (up to the amount of the accumulated gains)
• where there is no balance in the Revaluation Reserve or an insufficient balance, the carrying amount of the asset is charged to the statement of comprehensive net expenditure

Where asset revaluations give rise to impairment, an assessment is carried out to determine if the impairment is due to consumption of economic benefit and should be recognised in the statement of comprehensive net expenditure.

Disposals

When an asset is disposed of or decommissioned, the carrying amount of the asset is charged to the statement of comprehensive net expenditure as a loss on disposal. Receipts from disposals are credited to the statement of comprehensive net expenditure as a gain on disposal (that is, netted off against the carrying value of the asset at the time of disposal).

1.12 Provisions, contingent liabilities, and contingent assets

Provisions

In accordance with IAS 37 provisions are recognised when a legal or constructive obligation from a past event arises and an outflow of economic benefits will probably be required to settle the obligation, and the amount of the obligation can be assessed reliably.

For legal costs a provision is made when there is a probability of greater than 50% that the case will be lost and being ordered to pay costs. Legal cases are taken on by the EHRC to challenge and clarify the law, which may result in adverse judgment being made. The probability assessment is carried out on a case-by-case basis, taking the advice of external legal experts.

For dilapidations, outside the scope of IFRS 16, a provision is made for the estimated costs of returning premises to their original condition at the end of the lease period where there is an obligation contained in the lease.

If a value is not provided by the lessor within the lease the provision is calculated utilising a rate per square foot based on a professional valuation.

If an annual assessment to revalue the provision is not carried out, provisions held are discounted according to the HM Treasury discount rate (indicated in the table below) when their use is expected to be more than a year from the date of creation.

HMT General provisions discount rates	2023–24	2022–23
Short-term: applied on cash flows from up to and including five years from the date of the Statement of Financial Position	4.26%	3.27%
Medium-term: applied on cash flows from after five and up to and including 10 years from the date of the Statement of Financial Position	4.03%	3.20%

Contingent liabilities

A contingent liability arises where an event has taken place that gives the EHRC a possible obligation which will only be confirmed by the occurrence or otherwise of uncertain future events not wholly under the EHRC’s control. Contingent liabilities also occur when a provision would otherwise be made but it is not probable that an outflow of resources will be required, or the amount of the obligation cannot be measured reliably.

Contingent liabilities are not recognised in the financial statements but are disclosed in a note to the accounts.

Contingent assets

A contingent asset arises where an event has taken place that gives rise to a possible asset which will only be confirmed by the occurrence or otherwise of uncertain future events not wholly under our control.

Contingent assets are not recognised in the financial statements but disclosed in a note to the accounts when it is probable that there will be an inflow of economic benefits or service potential.

1.13 Access to Work scheme

The Access to Work scheme, run by the Department for Work and Pensions (DWP), considers if any reasonable adjustments are required for a person to do their job. If a member of staff has an agreement in place which provides part-funding for equipment or services, the EHRC agrees to make up any shortfall.

1.14 Pensions

Current and former employees are covered by the provisions of the Principal Civil Service Pension Scheme (PCSPS) and the Civil Servants and Other Pension Scheme (CSOPS).

The defined-benefit elements of the scheme are unfunded and non-contributory except in respect of dependents’ benefits. We recognise the expected cost of these elements on a systematic and rational basis over the period during which we benefit from employees’ services by paying into the PCSPS/CSOPS amounts calculated on an accruing basis.

Liability for payment of future benefits is a charge on the PCSPS/CSOPS. Regarding the defined-contribution elements of the scheme, we recognise the contributions payable for the year.

Pension benefits for former Chairs of the EHRC and its legacy organisations are provided under a ‘broadly by analogy’ scheme. The scheme disclosures are stated in accordance with IAS 19, Employee Benefits. This scheme is an unfunded defined-benefit scheme and pensions are administered in accordance with the standard rules (by analogy with the PCSPS).

Where actuarial gains and losses arise from changes to actuarial assumptions when revaluing future benefits, and from actual experience in respect of scheme liabilities and investment performance of scheme assets being different from previous assumptions, then the actuarial gains and losses are recognised directly in taxpayers’ equity for the year.

1.15 Leases (as a Lessee)

IFRS 16, effective from 1 April 2022 removed the distinction between operating and finance leases and requires lessees to recognise leases as ‘right of use’ assets and to disclose the corresponding liabilities for all leases, unless they are exempt due to the lease term being 12 months or less and/or the underlying asset having a low value (less than £5,000). In accordance with the FReM, occupancy agreements between government departments are treated as contracts and are within the scope of IFRS 16. IFRS 16 is not applied to intangible assets.

Recognition of assets

At the commencement of a contract, EHRC assesses whether the contract constitutes a lease by conveying the right to control the use of an identified asset for a period of time in exchange for consideration, including whether:

• the contract involves the use of an identified asset
• the EHRC has the right to obtain substantially all of the economic benefit from the use of the asset throughout the period of use
• the EHRC has the right to direct the use of the asset for the duration of the period of use

EHRC also assesses whether any break clauses or extension options are likely to be exercised at the lease commencement date. These assumptions are reassessed if there are significant events or changes in circumstances that were not anticipated at commencement.

Where the interest rate implicit in a lease cannot be readily determined, the lease liability is calculated using the HM Treasury discount rates provided in PES papers as the incremental borrowing rate.

Right of use assets

Right of use assets are initially measured at cost, which comprises the total of the lease liability and are subsequently measured at current value in existing use in line with property, plant and equipment assets, using cost as a proxy for fair value as significant market fluctuations are not anticipated.

The right of use asset is depreciated using the straight line method from the commencement date to the end of the lease term.

IAS 36 Impairment of Assets is applied in line with property, plant and equipment assets to determine whether the right of use asset is impaired and to account for any impairment loss identified.

Lease liabilities

The lease liability is initially measured at the present value of the lease payments that are not paid at the commencement date, discounted using the interest rate implicit in the lease, or if that cannot be readily determined, the rate provided by HM Treasury (HMT).

The discount rates applicable for the current reporting period are:

• for leases that commenced or are remeasured in the 2023 calendar year 3.51%
• for leases that commenced or are remeasured in the 2024 calendar year 4.72%

The lease payment is measured at amortised cost using the effective interest method.

It is re-measured when there is a change in future lease payments or if EHRC changes its assessment of whether it will exercise an extension or break option.

The EHRC does not currently act as a lessor.

1.16 Value Added Tax (VAT)

Most of the activities of EHRC are outside the scope of VAT and input tax on purchases is not recoverable. Irrecoverable VAT is charged to the relevant expenditure category or included in the capitalised purchase costs of fixed assets.

1.17 Related-party transactions

The EHRC is required to disclose material transactions with related parties, bodies or individuals that have the potential to control or influence our organisation or to be controlled or influenced by us.

Disclosure of these transactions allows readers to assess how the EHRC might have been constrained in its ability to operate independently or might have secured the ability to limit another party’s ability to bargain freely with us.

1.18 Events after the reporting period

Events after the reporting period are those, both favourable and unfavourable, that occur between the end of the reporting period and the date when the statement of accounts is authorised for issue. Two types of events can be identified:

• Adjusting events: Those events that provide evidence of conditions that existed at the end of the reporting period – the statement of accounts is adjusted to reflect such events.
• Non-adjusting events: Those events that are indicative of conditions that arose after the reporting period – the statement of accounts is not adjusted to reflect such events. However, where a category of events would have a material effect, disclosure is made in the notes regarding the nature of the events and either their estimated financial effect or a statement that such an estimate cannot be made reliably.

2. Statement of outturn by operating segment

Our operations are divided into networks, each led by a Senior Officer. These networks and the teams included in each are summarised below. During 2023–24, the EHRC’s reporting structure was re-organised, the tables below show the reporting responsibilities at 31 March 2024.

Chief Operating Officer network teams

• Communications, International and Correspondence
• Estates and Facilities, People and Information Technology
• Senior Management Team and Private Office
• Finance, Procurement, Planning and Governance
• Corporate Law and Information Governance
• Board and Committees

Regulation network teams

• Policy
• Strategy
• Human Rights Monitoring
• Evidence and Data
• Wales
• Scotland
• Compliance
• Legal and Enforcement

2023–24	Gross expenditure £000	Income £000	Net expenditure £000
Chief Operating Officer	8,646	(8)	8,638
Regulation	9,177	(20)	9,157
Total operating expenditure	17,823	(28)	17,795
Depreciation and amortisation charge	916	–	916
Interest cost on pension scheme liabilities	44	–	44
Interest cost on leases	12	–	12
Total net expenditure	18,795	(28)	18,767

The 2022–23 totals in the table below have been amended to provide comparatives for the previous year.

2022–23 (represented)	Gross expenditure £000	Income £000	Net expenditure £000
Chief Operating Officer	8,442	(106)	8,336
Regulation	9,000	(19)	8,981
Total operating expenditure	17,442	(125)	17,317
Depreciation and amortisation charge	912	–	912
Interest cost on pension scheme liabilities	21	–	21
Interest cost on leases	15	–	15
Total net expenditure	18,390	(125)	18,265

Capital expenditure, assets and liabilities are not reported to the CODM at a segmental level and have not therefore been included in the tables.

3. Expenditure

Category	2023 - 2024 £000	2022 - 2023£000
Staff Costs	-	-
Wages and salaries	10,556	9,578
Social security costs	1,167	1,103
Apprentice levy	39	35
Pension costs (PCSCS)	2,811	2,626
Pension costs (Partnership scheme)	15	6
Untaken annual leave	(22)	34
Inward secondments	40	158
Recoveries in respect of outward secondments	(169)	(115)
Agency staff	43	373
Exit packages	–	135
Board and Committee fees	208	223
Total staff costs[footnote 21]	14,688	14,156
Purchase of goods and services	-	-
ICT and telecommunications	700	741
Support and office services	528	640
Premises costs (non-lease)	510	552
Legal	378	491
Publication and information	244	223
Staff support, recruitment and training	201	206
Travel and subsistence	196	264
Advisory services	112	109
Auditor’s remuneration[footnote 22]	73	63
Rentals under operating leases	40	57
Access to work	40	31
Research and policy development	10	78
Total purchase of goods and services	3,032	3,455
Non-cash items	-	-
Depreciation of property, plant and equipment	409	363
Amortisation of intangible assets	72	115
Depreciation Right of Use assets	438	435
Gain/Loss on disposal of ROU assets	(3)	(1)
Revaluation of property, plant and equipment and intangible assets	–	–
Provision expense	103	(168)
Borrowing costs of provisions (unwinding of discount on provisions)	–	(1)
Total operating expenditure	18,739	18,354
Interest cost on pension scheme liabilities	44	21
Interest cost on IFRS16 Leases	12	15
Total net finance expenditure	56	36
Total expenditure	18,795	18,390

4. Income

Category	2023 - 2024 £000	2022 - 2023£000
Grants received	–	104
Access to work scheme	26	21
Other income	2	–
Total income	28	125

5. Plant, property and equipment

2023–2024	Leasehold improvement £000[footnote 23]	IT and telecoms equipment £000	Furniture £000	Payments on account and assets under construction £000	Total £000
Cost or valuation	-	-	-	-	-
At 1 April 2023	1,321	1,156	371	94	2,942
Additions in year	35	178	3	16	232
Reclassifications and transfers	94	–	–	(94)	–
Disposals	(22)	(359)	(19)	–	(400)
Revaluations	38	4	12	–	54
At 31 March 2024	1,466	979	367	16	2,828
Depreciation	-	-	-	-	-
At 1 April 2023	1,066	607	171	–	1,844
Charge in year	186	184	39	–	409
Disposals	(22)	(359)	(19)	–	(400)
Revaluations	30	2	6	–	38
At 31 March 2024	1,260	434	197	–	1,891
Carrying value	-	-	-	-	-
At 31 March 2023	255	549	200	94	1,098
At 31 March 2024	206	545	170	16	937

2022–2023	Leasehold improvement £000[footnote 23]	IT and telecoms equipment £000	Furniture £000	Payments on account and assets under construction £000	Total £000
Cost or valuation	-	-	-	-
1,357	1,417	344	7	3,125
153	216	24	94	487
(212)	(494)	(24)	–	(730)
7	–	–	(7)	–
16	17	27	–	60
1,321	1,156	371	94	2,942
Depreciation	-	-	-	-
1,065	970	150	–	2,185
205	125	33	–	363
(212)	(494)	(24)	–	(730)
8	6	12	–	26
1,066	607	171	–	1,844
Carrying value	-	-	-	-
292	447	194	7	940
255	549	200	94	1,098

Payments on account and assets under construction include ICT equipment currently being configured. These amounts include accruals and do not necessarily represent a cash outflow in the current year.

6. Intangible assets

2023–2024	Software £000	Total £000
Cost or valuation	-	-
At 1 April 2023	382	382
Additions	12	12
Disposals	–	–
Revaluations	1	1
At 31 March 2024	395	395
Amortisation	-	-
At 1 April 2023	317	317
Charge in year	72	72
Disposals	–	–
Revaluations	1	1
At 31 March 2024	390	390
Carrying value	-	-
At 31 March 2023	65	65
At 31 March 2024	5	5

2022–2023	Software £000	Total £000
Cost or valuation	–	–
At 1 April 2022	398	398
Additions	6	6
Disposals	(31)	(31)
Reclassification	–	–
Revaluations	9	9
At 31 March 2023	382	382
Amortisation	–	–
At 1 April 2022	226	226
Charge in year	115	115
Disposals	(31)	(31)
Revaluations	7	7
At 31 March 2023	317	317
Carrying value	–	–
At 31 March 2022	172	172
At 31 March 2023	65	65

7. Financial instruments

Due to the EHRC’s cash requirements being met through the estimate process of our sponsoring department, financial instruments play a more limited role in creating and managing risk than would apply in a non-public-sector body. Most financial instruments we hold relate to contracts to buy non-financial items in line with our expected purchase and usage requirements, therefore the exposure to credit, liquidity and market risk is considered minimal.

8. Cash and cash equivalents

Category	2023–2024 £000	2022–2023 £000
At 1 April	32	375
Net change in cash and cash equivalent balances	212	(343)
Balance at 31 March	244	32

9. Trade and other receivables

Category	2023–2024 £000	2022–2023 £000
Amounts falling due within one year	-	-
Receivables	33	8
Prepayments	544	586
Accrued income	10	2
Total falling due within one year	587	596
Amounts falling due after one year	-	-
Prepayments	54	85
Total receivables	641	681

10. Trade payables and other liabilities

Category	2023–2024 £000	2022–2023 £000
Amounts falling due within one year	-	-
Accruals	364	333
Trade payables	24	351
Other taxation and social security	335	315
Holiday pay accrual	286	308
Pension payments	278	280
VAT	10	4
Current part of lease liabilities	258	447
Total falling due within one year	1,555	2,038
Amounts falling due after one year	-	-
Non-current part of lease liabilities	599	857
Total payables	2,154	2,895

11. Provisions for liabilities and charges

Category	2023–2024 Dilapidation provision £000	2023–2024 Total provisions £000	2022–2023 Total provisions £000
Balance at 1 April	216	216	432
Provided in year	282	282	–
Provisions not required/written back	(179)	(179)	(168)
Provisions utilised	–	–	(47)
Unwinding of discount rate	–	–	(2)
Change in discount rate	–	–	1
Balance at 31 March	319	319	216

Ageing of provisions	2023–2024 Dilapidation provision £000	2023–2024 Total provisions £000	2022–2023 Total provisions £000
Not later than one year	37	37	–
Later than one and not later than five years	282	282	216
Later than five years	–	–	–
Total	319	319	216

12. Pension liabilities (retirement benefit obligations)

Pension liabilities comprise pension benefits for the former Chair of the EHRC and former Chairs and Deputy Chairs of legacy Commissions. The benefits are provided under a scheme broadly by analogy with the PCSPS.

The pension scheme is unfunded, with benefits being paid as they fall due and guaranteed by our organisation. There is no fund and therefore no surplus, deficit or assets. The Government Actuary’s Department, using the financial assumptions in the tables below, has calculated the scheme liabilities at 31 March 2024.

Assumptions %	2023–24 £000	2022–23 £000
Rate used to discount scheme liabilities	5.10	4.15
Rate of inflation: Consumer Prices Index	2.55	2.40
Rate of increase for pensions in payment and deferred pensions	2.55	2.40

Liabilities	2023–24 £000	2022–23 £000
Active members (past service)	–	–
Deferred pensioners	–	–
Current pensioners	1,166	1,126
Net present value of scheme liabilities*	1,166	1,126

Analysis of movement in scheme liability	2023–24 £000	2022–23 £000
Balance at 1 April	1,126	1,421
Net interest – recognised in net expenditure for the year	44	21
Actuarial loss/(gain) – in other comprehensive expenditure	111	(211)
Less benefits paid	(115)	(105)
Present value of scheme liabilities	1,166	1,126
Ageing of liabilities	-	-
Not later than one year	118	116
Later than one and not later than five years	472	470
Later than five years	576	540
Total	1,166	1,126

Actuarial gains/losses to be recognised in other comprehensive income	2023–24 £000	2022–23 £000
Experience loss/(gain) arising on the scheme liabilities	202	139
Changes in assumptions underlying the present value of the scheme liabilities	(91)	(350)
Net total actuarial loss/(gain) in other comprehensive expenditure	111	(211)

Experience loss arising on the scheme liabilities amounted to £202,000 (a £139,000 loss in 2022–23), changes in the demographic and financial assumptions underlying the valuation of the scheme have resulted in a gain to the scheme of £91,000 (a £350,000 gain in 2022–23). The total re-measurements were a loss of £111,000 (a £211,000 gain in 2022–23) recognised directly in taxpayers’ equity.

Experience loss/(gain) as a percentage of scheme liabilities	2023–24 £000	2022–23 £000
Experience loss/(gain) arising on the scheme liabilities	202	139
Net present value of the scheme liabilities	1,166	1,126
Percentage of scheme liabilities at the year end	17.30	12.30

The sensitivity analysis of Scheme Liabilities defined benefit obligations (DBO) to changes in the significant actuarial assumptions (keeping all other assumptions unchanged) indicates the following:

Category	Growth	%	£
Rate of discounting scheme liabilities	+ 0.5% a year	(4)	(46)
Rate of increase in CPI	+ 0.5% a year	4	45
Life expectancy – each member assumed 1 year younger that their actual age		3	37

Opposite changes in assumptions to those above would produce approximately equal and opposite changes in the DBO. Similarly, doubling the changes in the assumptions will produce approximately double the changes in the DBO. The sensitivities show the changes in each assumption in isolation. In practice, such assumptions rarely change in isolation and given the interdependencies between them, the impacts may offset to some extent.

The longevity assumptions used in the valuation of the scheme are detailed in the table below:

31 March 2024

31 March 2023

Current pensioners Exact age	31 March 2024 Men (yrs)	31 March 2024 Women (yrs)	31 March 2023 Men (yrs)	31 March 2023 Women (yrs)
60	26.7	28.2	26.6	28.1
65	21.9	23.3	21.8	23.2

13. Leases

IFRS 16 Leases has been implemented from 1 April 2022. Leases previously recognised as operating leases, along with new leases acquired that meet the requirements of IFRS 16 are now recognised as right-of-use assets at an amount equal to the initial lease liability, adjusted by any rent free periods, other associated costs and VAT payable. The corresponding liability is calculated based on the present value of future cash flows for each lease over the applicable lease term.

The EHRC’s current lease contracts comprise the rental of office space, no new agreements commenced and one lease ended during the reporting period, the remaining leases relate to premises at three locations Cardiff, London and Manchester.

Right of Use assets 2023–24	Office leases £000
Cost or valuation	-
At 1 April 2023	1,772
Additions in year	–
Disposals	(50)
Revaluations	–
At 31 March 2024	1,722
Depreciation	-
At 1 April 2023	429
Charge in year	438
Disposals	(50)
Revaluations	–
At 31 March 2024	817
Carrying value	-
At 31 March 2023	1,343
At 31 March 2024	905

Right of Use assets 2022–23	Office leases £000
Cost or valuation	–
At 1 April 2022	–
Additions (resulting from IFRS16 adoption 1 April 2022)	1,572
Additions in year	326
Disposals	(126)
Revaluations	–
At 31 March 2023	1,772
Depreciation	–
At 1 April 2022	–
Charge in year	435
Disposals	(6)
Revaluations	–
At 31 March 2023	429
Carrying value	–
At 31 March 2022	–
At 31 March 2023	1,343

Lease liabilities

Total future lease obligations are given below:	2023–24 £000	2022–23 £000
Office leases	-	-
Total future lease obligations are given below:	-	-
Not later than one year	264	459
Later than one year but not later than five years	553	801
Later than five years	56	71
Less interest element	16	27
Present value of obligations	857	1,304
Current portion	258	447
Non-current portion	599	857

Lease elements within the Statement of Comprehensive Net Expenditure

Elements in the Statement of Comprehensive Net Expenditure	2023–24 £000	2022–23 £000
Office leases	-	-
VAT element of lease payments	40	57
Depreciation	435	435
Interest expense	12	15

14. Capital commitments

Significant commitments	31 March 2024	31 March 2023
Completion of fit-out of Cardiff office	–	47
ICT equipment refresh	7	115
ICT licenses	–	12
Total	7	174

15. Contingent liabilities disclosed under IAS 37

At 31 March 2024, no contingent liabilities exist (two on 31 March 2023).

16. Related party transactions

The EHRC is a non-departmental public body sponsored by the Cabinet Office which is regarded as a related party.

During the year funding of £18.973 million was received from the Cabinet Office in the form of grant-in-aid. No other significant transactions have taken place.

The EHRC leases premises managed by the GPA, which is an executive agency of the Cabinet Office and payments have been made to the GPA in respect of rent and other costs associated with the leases. Transactions have also taken place with other government departments in the normal performance of EHRC’s functions.

The EHRC does not have any subsidiaries.

No board member or manager has undertaken any transactions with the EHRC during the reporting period except for remuneration and re-imbursement of expenses incurred which is reported on pages 90–96.

17. Events after the reporting period

EHRC made a provision at 31 March 2024 regarding the Chairwoman’s legal expenses incurred totalling £15,793 while HMT consent to pay these was sought. Approval to pay these was subsequently received on 19 June 2024, the provision was reversed and an accrual made to reflect the liability.

Authorised for issue

The accounts have been authorised for issue by the Accounting Officer on the same date as the Comptroller and Auditor General’s Audit Certificate.

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1. The Chairwoman was recused from one meeting of the Board ↩

2. Martyn Jones was co-opted to the Board and attended meetings as a representative for the Wales Committee from 23 November 2023 in the absence of a Wales Commissioner ↩

3. Bethan Thomas took a period of parental leave during the year and was unavailable for two committee meetings ↩

4. Organisations and individuals that are listed in The Public Interest Disclosure (Prescribed Persons) Order 2014 are referred to as prescribed persons. Prescribed persons have a role in the whistleblowing process. This role is influenced by the statutory functions specific to each body ↩

5. The Chairwoman is remunerated at a rate of £500 per day and is expected to work for up to 100 days per annum (total fees £50,000 per annum). Deputy Chairs are remunerated at a rate of £450 per day and are expected to work for up to 52 days per annum (total fees £23,400 per annum). Commissioners are remunerated at a rate of £400 per day and are expected to work for up to 25 days per annum (total fees £10,000 per annum). Chairs of the Audit and Risk, People and Workplace, Wales and Scotland Committees are remunerated at a rate of £400 per day and are expected to work for up to 30 days per annum (total fees £12,000 per annum) ↩

6. 2023–2024 expenses include legal expenses of £15,793 approved by HMT. See note 17 to the accounts on page 165 ↩

7. Resigned as Deputy Chair on 28 September 2023, she continued as Wales Commissioner for the duration of her appointment as a Commissioner ↩

8. Appointed Chair of the People and Workplace Committee from 1 October 2023 ↩

9. Resumed appointment as a Commissioner on 28 September 2023 following resignation as Deputy Chair ↩

10. Appointed Interim Deputy Chair 28 September 2023, fees paid after this date are shown in table c above ↩

11. Sue-Mei Thompson took an unremunerated leave of absence from 1 October 2023 for five months ↩

12. Accrued pension benefits for directors are not included in this table for 2023/24 due to an exceptional delay in the calculation of these figures following the application of the public service pensions remedy. ↩

13. Marcial Boo resigned on 2 January 2024. Marcial received contractual pay in lieu of notice and payment in lieu of untaken leave of £40,000 – £45,000. ↩

14. Melanie Field resigned on 31 October 2023. Notional Pension Benefits for 2022–23 for Melanie Field are negative due to transfer into the Alpha pension scheme. ↩

15. From 2 October Cath Denholm was appointed as acting Chief Executive and received remuneration in line with the permanent Chief Executive from this date until the end of the reporting period. ↩

16. John Kirkpatrick was appointed Deputy Chief Executive and joined the EHRC on 17 October 2023. ↩

17. Jackie Killeen was on secondment to the EHRC from the British Council. The secondment ended on 30 June 2023. The figures in the above table have been provided by the British Council based on the Salary agreed by EHRC. ↩

18. HM Government announced a one-off payment to all eligible staff of upto £1,500 paid during 2023–24. ↩

19. Untaken annual leave represents the movement in the accrual based on the calculated cost of leave not taken at 31 March 2024. The increase is due to a change in the annual leave year which is now based on joining date rather than the 1 April for all staff. ↩

20. Represents outward secondments during the reporting period where the employee remains on EHRC’s payroll and costs are recovered. ↩

21. Further detail is provided in the ‘Remuneration and staff report’ (page 89) ↩

22. No non-audit services were provided by the external auditors ↩

23. Leasehold improvement costs include the costs of fitting out premises that are occupied under a lease; such assets are depreciated over the term of the lease ↩ ↩²