Corporate report

Ethnicity Pay Gap Report: 1 April 2020 to 31 March 2021

Published 27 January 2022

Foreward

This is the second year we are voluntarily publishing our ethnicity pay gap report. Equality, diversity and inclusion are of fundamental importance at the CMA, and we believe that the continued publication of this report is an important tool to help us achieve our ambition to fully embed a diverse and inclusive culture. We actively listen to staff feedback, seek improvements and proactively develop plans to make the CMA an even better place to work.

In calculating our ethnicity pay gaps, we have used the same principles that are applied to statutory gender pay gap reporting. The ethnicity pay gap shows the difference in the average pay between staff from minority ethnic background in the workforce, compared to white staff. However, this year we have taken the step to present outcomes for specific ethnic minority groups. This recognises that there may be differences in the outcomes between specific groups, and it is important to recognise these differences. However, where analysis by each ethnic minority group would break down data into small sample sizes (for example, pay gap analysis by grade), outcomes have been reported overall as ‘all ethnic minority groups’. Where this occurs, this is noted in the report.

Our ethnicity pay gap figures continue to be of considerable concern to us as an organisation, and will continue to be a focus for us going forward. A significant driver of our ethnicity pay gap continues to be a simple structural reason: we still have too few ethnically diverse colleagues in senior roles. Over the past year, we have worked hard to try to address this issue and are pleased with key initiatives to help ethnically diverse colleagues progress in their careers and build the skills needed to be successful in more senior roles at the CMA. This includes a mutual mentoring programme, targeted skills development programmes and an innovative sponsorship programme, and we are tracking the impact of these initiatives on colleagues’ careers. We do, however, know that we need to do more to improve in this area.

Our key areas of focus to address our ethnicity pay gap over the coming years will be to continue to support and champion ethnically diverse staff and address the lack of ethnic diversity in our leadership population. Our second Race Action Plan for 2022 to 2023 details our commitment to delivering these objectives. We anticipate that the implementation and achievement of the second Race Action Plan’s actions will go some way towards reducing the ethnicity pay gap in the CMA.

Our board and executive team are fully committed to reducing our ethnicity pay gaps and understand that this will require sustained effort from us as an organisation. The board and the executive team fully endorse the range of initiatives detailed within this plan to ensure that we do all we can to close our ethnicity pay gaps.

Andrea Coscelli, Chief Executive

Amelia Fletcher, Non-Executive Director and Wellbeing, Inclusion, Diversity and Equality Steering Group (WIDE) Chair

Introduction

The CMA is a non-ministerial government department in the United Kingdom responsible for promoting competition for the benefit of consumers, both within and outside the UK. Our aim is to make markets work well for consumers, businesses and the economy, strengthening business competition and preventing and reducing anti-competitive activities.

As an organisation, the CMA remains committed to promoting equality, diversity and inclusion amongst our workforce. In August 2020, we published our ‘Equality, Diversity and Inclusion Strategy 2020 to 2024’ and ‘Equality, Diversity Action Plan 2020 to 2022’ which set out our ambitious programmes of work which seek to embed a diverse and inclusive culture within the CMA. We continue to take steps to minimise the ethnicity pay gap and our approach to pay seeks to reward staff fairly, regardless of ethnicity.

This report sets out the CMA’s ethnicity pay gap and the CMA’s action plan to address the gap.

Context

The background to racial disparity in the UK is well documented in a range of recent reviews and reports that outline the challenges and opportunities for employers in achieving workplace equality.

At the CMA, we have a clearly stated commitment to racial equality. As a signatory to the Race at Work Charter, the publication of this Ethnicity Pay Gap reports fulfils our charter commitment to ‘capture ethnicity data and publicise progress’.

Unlike gender pay gap reporting, ethnicity pay gap reporting is completed on a voluntary basis. Of those organisations that have published ethnicity pay gap data, there is a trend towards a concentration of staff from ethnic minority backgrounds in junior roles and an absence or under-representation of these staff at senior levels. However, as reporting is currently voluntary, there is limited data available to allow us to compare ourselves to other organisations.

The CMA ethnicity pay gap is driven largely by similar challenges, as identified in the CMA’s first Ethnicity Pay Gap Report for 2019 to 2020. While we are pleased to see an ongoing increase in representation of staff from ethnic minority backgrounds since 2015, the low concentration at higher grades remains a significant issue for the CMA for many reasons, including being a substantial driver of our ethnicity pay gap figures. We have already put a range of measures in place to address underrepresentation at senior grades, particularly within the SCS.

Ethnicity Pay Gap Reporting

What is the Ethnicity Pay Gap?

The ethnicity pay gap shows the difference in the average pay between staff from ethnic minority backgrounds in a workforce, compared to ‘White’ staff.

Where there is a positive percentage, this means that the average pay of a White member of staff is higher than that of a member of staff from an ethnic minority group. The higher the percentage, the greater the ethnicity pay gap. A negative pay mean means that the average pay of the ethnic minority group is higher than that of the White group.

The ethnicity pay gap is different to equal pay. Ethnic pay disparities are not primarily about those from a White background and other ethnic groups being paid differently for the same job. The Equality Act 2010 makes it unlawful to discriminate (both directly and indirectly) against employees because of their race. Therefore, unless there is a failure to comply with existing law, pay disparities between ethnic groups are likely to be due to other factors that impose a disadvantage on people from ethnic minority backgrounds without being explicitly discriminatory.^{[footnote 1]}

Development of Employer Guidance

In October 2018, as part of the government response to the McGregor-Smith recommendations, the Department for Business, Energy and Industrial Strategy (BEIS) initiated an employer consultation on ethnicity pay gap reporting. The consultation set out questions and options on what ethnicity pay information should be reported by employers to allow for meaningful actions to be taken.

In June 2020, the Commission on Race and Ethnic Disparities (CRED) was established by the UK government. The purpose of CRED, with support from the Race Disparity Unit of the Cabinet Office, is to investigate race and ethnic disparities in the UK.

In April 2021, CRED made a set of recommendations on ethnicity pay gap reporting published in the The report of the Commission on Race and Ethnic Disparities. It is expected that these recommendations – and the findings from the BEIS employer consultation – will inform ethnicity pay gap reporting guidelines for employers, however these guidelines have not yet been published.

CMA Approach to Ethnicity Pay Gap Reporting

In the absence of employer guidance, the CMA has taken the approach to align with the recommendations set out by CRED. This includes moving away from using the term ‘BAME’ to better understand disparities and outcomes for specific ethnic groups. Therefore, as an update from last year’s report, this year’s report presents outcomes for specific ethnic minority groups:

• Black (including Black Caribbean and Black African)
• Asian (including Indian, Pakistani, Bangladeshi, Chinese, and other Asian categories)
• Mixed (including any mix of the above categories, including White)
• Other - This is where staff have disclosed that their ethnicity does not fall into the above categories or any of the White ethnic groups.

It is acknowledged that there may be differences in the outcomes between specific groups within the above categories (for example, Indian and Chinese). However, due to the small sample sizes within these sub-groups, the outcomes are reported within each of the above categories. In addition, where analysis by each ethnic minority group would break down data into small sample sizes (e.g. pay gap analysis by grade), outcomes have been reported overall as ‘all ethnic minority groups’.

There is no guidance on the pay measures that need to be reported as part of Ethnicity Pay Gap reporting nor any guidance on the methodology for calculation. Therefore, the CMA has taken the approach to mirror the legislated pay measures used for Gender Pay Gap reporting,^{[footnote 2]} and the methods of calculation, but applied through a lens of ethnicity (where outcomes for ethnic minority groups are compared against White ethnic groups). Therefore, the pay measures contained in this report are:

• the mean and median ethnicity pay gaps for each ethnic minority group, compared against White ethnic groups
• the mean and median ethnicity bonus gaps for each ethnic minority group, compared against White ethnic groups
• the proportion of each ethnic group who received bonuses
• the proportion of employees in each pay quartile for each ethnic group

Ethnicity Profile of the CMA

At 31 March 2021, the CMA had a total of 835 staff^{[footnote 3]} in the UK with 781 based in London, 48 in Edinburgh, 3 in Cardiff and 3 in Belfast. This is the number of staff deemed to be ‘full pay relevant’; those employees who are not being paid or are on reduced, statutory or no pay during March 2021 are excluded as they are not ‘full pay relevant’ employees.

The ethnicity profile of full pay relevant CMA staff at 31 March 2021 is below:

Figure 1: CMA Ethnicity Profile by grade as of 31 March 2021

Grade	All Staff	White	Black	Asian	Mixed	Other	All Ethnic Minority Groups	Not Reportable*
AO, EO, HEO, SEO	299	53.8%	9.7%	22.4%	6.0%	1.3%	39.5%	6.7%
G7, G6	425	72.2%	2.1%	9.6%	4.7%	1.4%	17.9%	9.9%
SCS PB1, PB2, PB3	111	83.8%	n/a	n/a	n/a	n/a	1.8%**	14.4%
Percentage of all staff	835	67.2%	4.6%	13.2%	4.6%	1.2%	23.5%	9.3%

*This covers all full pay relevant employees who have chosen the ‘Prefer not to say’ option or who have not disclosed their ethnicity.

**The profile of ethnic minority staff at SCS grades has been combined to avoid disclosure of individual ethnic backgrounds, due to small population sizes

Grade	All staff
AO	27
EO	76
HEO	141
SEO	55
G7	232
G6	193
SCS PB1	87
SCS PB2 / PB3	24

A breakdown of the number of staff at each grade within the CMA.

We know that there is higher representation of staff from ethnic minority backgrounds at junior grades, as well as lower representation of these staff at senior grades relative to the overall CMA population.

In particular, the low proportion of staff from ethnic minority backgrounds in the SCS is unacceptable and is a priority focus for the CMA Board and Senior Executive Team. The ambition is that the organisational diversity of the CMA at all levels should reflect that of the UK public and the consumers we serve, and we will take all possible steps to achieve this ambition.

It should be highlighted that the proportion of staff from ethnic minority backgrounds within the CMA has increased from 22.0% in 2019 to 2020 to 23.5% in 2020 to 2021, owing to the diversity of new joiners (where a third were of ethnic minority backgrounds). This compares favourably to the wider Civil Service where only 13.2% of employees were of ethnic minority backgrounds in August 2020.^{[footnote 4]}

Representation in the SCS has improved slightly from 0.0% in 2019 to 2020 to 1.8% in 2020 to 2021. We hope that this will improve further in 2021 – 2022 because of the additional appointments we have made to the SCS community in 2021 to 2022. In the wider Civil Service, the representation of staff from ethnic minority backgrounds at SCS grades is 9.1% as at August 2020.^{[footnote 5]}

As the CMA grows in 2021 to 2022 and subsequent years to take on additional responsibilities with the Office for Internal Markets, Subsidy Advice Unit and Digital Markets Unit, we are optimistic that many of these new roles – particularly those at SCS – can be filled with more diverse voices, including those of ethnic minority backgrounds. Improving the ethnicity balance in senior grades will be 1 of the key ways in which we will reduce the pay gaps at the CMA.

Calculating the Ethnicity Pay Gap

Ordinary Pay

Ordinary pay, expressed as hourly pay, is used to calculate the mean and median ethnicity pay gaps. Ordinary pay includes basic pay, any allowances and any bonus payments made in March 2021. Salary sacrifice amounts are deducted from this value.

The calculation for the mean and median ordinary pay only includes ‘full pay relevant’ employees; that is, those employees who were on full pay in March 2021.

It should be noted that pay gap calculations are based on the number of individual employees, and not on full-time equivalents. This means that each part-time employee counts as 1 employee.

The following table shows the mean pay gap (the difference in the average hourly pay for each ethnic group compared to the White ethnic group) and the median pay gap (the difference in the median hourly pay for each ethnic group compared to the White ethnic group). The 2019 to 2020 pay gaps have been provided for comparison.

Figure 2: Mean and median ethnicity pay gaps for 2020 – 2021

Ethnic Group	2020 / 2021 Mean Pay Gap	2020 / 2021 Median Pay Gap
Black	28.8%	33.8%
Asian	33.0%	25.9%
Mixed	10.2%	24.5%
Other	7.8%	10.7%
All Ethnic Minority Groups	26.4%	28.8%

2019 / 2020 Mean Pay Gap*	2019 / 2020 Median Pay Gap*
29.3%	34.8%

*Ethnic minority groups were reported collectively as ‘BAME’ in 2019 to 2020 so individual pay gaps are not available for each ethnic group

The most significant factor in our ordinary pay gaps is the distribution of our ethnic minority staff – specifically, the overrepresentation at junior grades and underrepresentation at senior grades (as shown in Figure 1). This applies to each of our ethnic groups but particularly so for Black and Asian ethnic groups, where 76.3% and 60.9% of these groups, respectively, are in grades AO to SEO.

As a smaller department, we know that our ethnicity pay gaps can be affected by small changes to our ethnic representation and pay. We know that the ordinary pay gaps are also caused by the following contributing factors:

• The CMA has differentiated ‘competition specialist’ pay ranges for Grade 7, Grade 6, SCS PB1 and SCS PB2. While we have consolidated reporting at each grade, it should be noted that the competition specialist pay ranges have higher starting salaries, and higher maximum salaries compared to non-competition specialist roles where there is a higher proportion of ethnic minority staff; and
• Digital, Data and Technology (DDaT) allowances were introduced in the 2020 to 2021 financial year. These allowances are paid to eligible DDaT roles – defined by the Government Digital Service (GDS) who centrally own the DDaT Framework – to address attraction and retention issues across government due to the scarcity of professionals in the job market. Of those staff who received allowances for holding eligible roles, 23.1% of these were of Asian backgrounds. All other recipients were from White ethnic backgrounds. We also note that the allowances paid to White staff were 43.5% higher due to White staff, generally, occupying more senior roles and / or evidencing higher capability levels through the capability assessment process.

We are pleased to see a positive direction of travel with reductions in the mean pay gap by -2.9% and the median pay gap by -6.0% for all ethnic minority groups since 2019 to 2020. The factors which have contributed to reducing these pay gaps include:

• In our 2020 to 2021 Pay Settlements, we made pay awards based on staff position within their respective pay range (with those lowest in the pay range receiving the highest pay awards). This has the effect of providing accelerated pay progression for those lowest in their pay range, while incrementally reducing differences in pay based on length of service; we note that staff of ethnic minority backgrounds have, on average, shorter lengths of service within the CMA; and *Of the reportable joiners from ethnic minority backgrounds, more than 2 thirds (69.0%) joined in roles at SEO or above. This is also the case when we consider each ethnic group, where the majority of Black (100.0%), Asian (58.3%), Mixed (57.5%) and Other (66.7%) staff joined in roles at SEO or above. While the recruitment profile was similar for White joiners, these increases to the ethnic representation of our more senior delegated grades are meaningful as ethnic minority groups have historically been underrepresented.

The following table shows the mean and median ethnicity pay gaps for 2020 to 2021 broken down by grade*. These have been reported as a combination of all ethnic minority groups rather than providing a breakdown for each ethnic group due to the small population sizes within each grade.

Figure 3: Mean and median ethnicity pay gaps by grade for 2020 to 2021

Grade	All Ethnic Minority Groups Mean Pay Gap*	All Ethnic Minority Groups Median Pay Gap*
AO	-2.7%	-1.9%
EO	2.4%	2.7%
HEO	0.3%	0.2%
SEO	1.1%	-2.9%
G7	2.0%	0.7%
G6	-1.8%	-2.9%
SCS PB1	2.9%	2.7%
SCS PB2 / PB3	N/A	N/A
All Staff	26.4%	28.8%

*Where we have a negative percentage, this means that the average pay of staff within the relevant cohort is higher than the pay of White staff at the same grade.

Looking at the mean and median pay gaps by grade, the data shows that there are only minor gaps (no more than 3.0%) at all grades with some grades evidencing higher average pay for ethnic minority staff. As described in paragraph 30(a), the small gaps can be attributed to our decision in our 2020 to 2021 Pay Settlements to make pay awards based on staff position within their respective pay range (with those lowest in the pay range receiving the highest pay awards). Our Pay Policy also sets out rules for salaries on appointment which limits starting salaries to the grade minimum up to the grade midpoint; this has the effect of limiting differences in pay between existing staff and new starters which also has the potential to negatively impact our pay gaps.

The mean and median pay gaps by grade should be contrasted with the overall CMA mean and median pay gaps of 26.4% and 28.8%, respectively (presented at Figure 2). While the pay gaps at a grade level are minimal, the overall CMA mean and median pay gaps are primarily driven by the under-representation of ethnic minority staff in senior grades, particularly in the SCS, relative to their population in the organisation. We expect that our Action Plan, specifically the actions to address under-representation of staff from ethnic minority backgrounds at senior grades, will enable us to reduce these gaps in future years. Bonus Pay

Bonus pay, which is also calculated as mean and median, is based on bonus payments paid to staff throughout the 2020 to 2021 financial year.

As this covers a full year period, this calculation includes employees who are not ‘full pay relevant’, such as those on reduced pay due to statutory leave (for exmaple, maternity , paternity, sick leave, etc.) and staff who were on nil pay during March 2021 (e.g. those on unpaid career breaks). Employees who left the CMA before 31 March 2021 are excluded from the calculation, in line with the guidance from the Cabinet Office for Gender Pay Gap reporting.

At the CMA, bonus pay includes performance related payments for all staff. These are payments based on performance management outcomes for the previous financial year. In the case of staff in grades AO to Grade 6, these payments are negotiated annually with our recognised trade unions. For SCS staff, there are separate arrangements which are centrally set by government each year.

In addition, staff in grades AO to Grade 6 have a Staff Recognition Scheme which provides non-consolidated cash awards between £25 and £750. Any scheme awards made during the 2020 to 2021 financial year are also included in bonus pay calculations.

It should be noted that bonus calculations must also include ‘Pivotal Role Allowances’. These are payments, approved by a subgroup of the Civil Service Board and Chief Secretary to Treasury, aimed at retaining SCS staff in highly specialised roles and those delivering high-risk, major projects within the Civil Service. The allowances were paid to a small number of SCS staff in the 2020 to 2021 financial year on completion of project milestones.

Taking into account all types of bonus payments, the proportion of staff in receipt of bonuses by ethnic group is set out below. The 2019 to 2020 proportions have also been provided for comparison.

Figure 4: Proportion of staff in receipt of bonuses for 2020 to 2021

Ethnic Group	2020 / 2021
White	69.8%
Black	63.2%
Asian	62.2%
Mixed	66.7%
Other	70.0%
All Ethnic Minority Groups	63.6%

Ethnic group	2019 / 2020*
White	68.0%
All Ethnic Minority Groups	76.6%

*Ethnic minority groups were reported collectively as ‘BAME’ in 2019 to 2020 so individual outcomes are not available for each ethnic group.

We note that there are decreases to the proportion of staff from ethnic minority groups that received bonuses when compared to 2019 to 2020. We attribute this to the fact that organisational awards were not awarded in 2020 to 2021, whereas they were awarded to the majority of staff in grades AO to Grade 6 in 2019 to 2020; this has a particular impact on ethnic minority groups as all staff of these groups in 2019 to 2020 were in grades AO to Grade 6.

The following table shows the mean bonus gap (which is the difference in the average bonus pay for each ethnic group compared to the White ethnic group) and the median bonus gap (which is the difference in the median bonus pay for the of each ethnic group compared to the White ethnic group). The 2019 to 2020 bonus gaps have been provided as a comparator:

Figure 5: Mean and median bonus pay gaps for 2020 – 2021

Ethnic Group	2020 / 2021 Mean Bonus Gap	2020 / 2021 Median Bonus Gap
Black	60.8%	42.9%
Asian	53.4%	58.2%
Mixed	57.6%	65.3%
Other	67.2%	55.4%
All Ethnic Minority Groups	56.4%	59.3%

Ethnic Group	2019 / 2020 Mean Bonus Gap*	2019 / 2020 Median Bonus Gap*
All Ethnic Minority Groups	57.9%	44.2%

*Ethnic minority groups were reported collectively as ‘BAME’ in 2019 to 2020 so individual pay gaps are not available for each ethnic group.

We know that the bonus gap continues to be affected by the following factors:

• The value of bonuses for SCS staff is significantly higher than staff in grades AO to G6. This is due to the size of the ‘performance pay pots’ which are set centrally by government; eligible SCS staff share 3.3% of the previous year’s SCS paybill for bonuses, while eligible staff in grades AO to Grade 6 share 1.5% of the previous year’s paybill for both performance related payments and Staff Recognition Scheme payments. The difference in the size of the pots, coupled with the fact that no ethnic minority staff in the SCS were eligible to receive a bonus due to time in role, widens the bonus gap significantly.
• Performance related payments made in 2020 to 2021 for staff in grades AO to Grade 6 were tiered based on a fixed proportion of each grade’s minimum salary. Given that these payments were tiered, and ethnic minority staff are overrepresented in junior grades, relative to their population, this has contributed to the bonus pay gaps.
• The inclusion of Pivotal Role Allowances in bonus calculations, as all current recipients fall under the White category.

The following table shows the mean and median ethnicity bonus gaps for 2020 to 2021 broken down by grade. These have been reported as a combination of all ethnic minority groups rather than providing a breakdown for each ethnic group due to the small population sizes within each grade.

Figure 6: Mean and median ethnicity bonus gaps by grade for 2020 to 2021

Grade	All Ethnic Minority Groups Mean Bonus Gap*	All Ethnic Minority Groups Median Bonus Gap*
AO	12.1%	6.1%
EO	38.5%	37.5%
HEO	9.3%	0.0%
SEO	-50.6%	-150.0%
G7	-9.0%	59.5%
G6	12.1%	24.3%
SCS PB1	N/A	N/A
SCS PB2 / PB3	N/A	N/A

*Where we have a negative percentage, this means that the average bonuses of staff within the relevant cohort is higher than the average bonuses of White staff at the same grade.

Looking at the mean and median bonus gaps by grade, we note that there are gaps at most grades. We attribute these gaps to the following factors:

• Of ethnic minority staff in receipt of bonus payments in 2020 to 2021, 59.5% of these were for staff who only received Staff Recognition Scheme payments (compared to 46.2% for staff in the White category). This is a major contributor to the large pay gaps for grades AO to Grade 6 as Staff Recognition Scheme payments are significantly lower (between £25 to £750) than PRPs (between £700 and £4,500 depending on grade and performance rating). We note that the average values of Staff Recognition Scheme payments were broadly similar for all groups, with staff of Asian and Black backgrounds more likely to receive the highest award values.
• Of ethnic minority staff in receipt of a performance related payment in 2020 to 2021, we note that 60.7% of these were awarded on the basis of ‘Partially Exceeding’ ratings. Less ethnic minority staff received a ‘Consistently Exceeding’ rating compared to staff in the White category. This is relevant as staff in receipt of a ‘Partially Exceeding’ rating were awarded 50% of the PRP value awarded to ‘Consistently Exceeding’ staff of the same grade; and
• As described in ordinary pay, there are higher minimum salaries for our ‘competition specialist’ pay ranges at Grade 7 and Grade 6. It should also be noted that performance related payments were calculated as a fixed percentage of the grade minima in 2020 to 2021, as in previous years. Given that there is a higher proportion of ethnic minority colleagues in non-competition specialist roles at Grade 7 and Grade 6, this has implications on the bonus pay gaps at these grades specifically as the value of performance related payments would have been lower.

Pay Quartiles

The hourly pay quartiles are calculated by listing all employees in order of hourly pay and splitting them into 4 equal parts. The chart below shows the proportion of staff by ethnicity that are in each pay quartile.

Figure 7: Proportion of staff by ethnic group in each pay quartile for 2020 – 2021

A bar chart in which the vertical axis shows the pay quartiles and the horizontal axis shows the proportion of staff from Asian, Black, Mixed, Other and White ethnic groups in each pay quartile.

The chart shows that the White staff make up the largest proportion of each pay quartile, and the proportion of staff from ethnic minority groups decreases as the pay quartile increases.

In the lower quartile the proportions are: White staff 59%, Asian staff 23.6%, Black staff 8.2%, staff from a mixed background 7.2% and staff identifying as Other 2.1%. In the lower middle quartile the proportions are: White staff 68%, Asian staff 16.2%, Black staff 9.1%, staff from a mixed background 6.1% and staff identifying as Other 0.5%. In the upper middle quartile the proportions are: White staff 82.1%, Asian staff 10.5%, Black staff 1.6%, staff from a mixed background 4.7% and staff identifying as Other 1.1%. In the upper quartile the proportions are: White staff 89.1%, Asian staff 6.9%, Black staff 0.6%, staff from a mixed background 1.7% and staff identifying as Other 1.7%.

The concentration of staff from ethnic minority backgrounds in the lower quartile reflects the overall ethnic profile of the CMA and the fact that these staff are in more junior roles. The upper quartile, which is mainly comprised of Grade 6 competition specialists and SCS staff, has the lowest proportion of ethnic minority staff. Increasing ethnic minority representation at senior grades, particularly the SCS, will improve the ethnicity balance in the upper quartile and reduce our pay gaps.

Closing the Gap – Actions for the CMA

The CMA agreed a Race Action Plan 2020 to 2021 which has begun to deliver an ambitious set of challenges that will see the CMA supporting and championing staff from ethnic minority groups and addressing the underrepresentation of staff from ethnic minority backgrounds at a senior level. We are continuing to make progress to deliver these programmes of work in the 2021 to 2022 financial year, where race remains a key area of focus in our equality, diversity and inclusion activity. The following 4 commitments are set out within our 2020 to 2021 plan:

• Action 1: Investigate ways to ensure greater ethnic diversity and diversity of thought at the senior leadership level
• Action 2: Sponsorship and the creation of an internal CMA development programme for aspiring colleagues from under-represented groups
• Action 3: Use data to challenge and check our progress on recruitment outcomes and pay and also review the CMA’s ethnicity pay gap
• Action 4: Creation of the Positive Action Steering Group (PASG)

It is anticipated that the implementation and achievement of these actions will go some way towards reducing the ethnicity pay gap in the CMA in the future. A brief overview of how we anticipate the identified actions will make a difference is outlined in the following table.

Race Action Plan 2020 to 2021 Commitment	What we have done and what we will continue to do
Investigate ways to ensure greater ethnic diversity and diversity of thought at the senior leadership level	The CMA Board and Executive want to ensure that the voice of under-represented groups, with a particular focus at the current time towards colleagues from ethnic minority backgrounds, are heard, understood and integral to senior level decision making in the CMA. The CMA’s new Advisory Committee has recently been established and has been operating since September 2021. 9 members were appointed and trained, including an external chair of an ethnic minority background. More broadly, our work on cultural awareness, respect, and close working with our staff networks will ensure that we create an open and inclusive working environment throughout the CMA where all voices can be shared and heard.
Sponsorship and the creation of an internal CMA development programme for aspiring colleagues from under-represented groups	Executive sponsorship is often cited as 1 of the most effective ways of developing diverse talent. Our Sponsorship programme, Accelerate, is a 12 month programme providing focused development and support for our talented aspiring colleagues from underrepresented groups. It has been designed to provide challenge and support to enable colleagues to progress their careers within the CMA. We currently have 3 Grade 6 ethnically diverse colleagues participating in the scheme sponsored by SET members and 3 Grade 7 ethnically diverse colleagues sponsored by Senior Directors. A lessons learnt exercise will be run to determine how and whether the CMA should include this Sponsorship offer in its regular yearly programme offer and what characteristic(s) it should focus on. The Aspire development programme was also created, providing a range of skills development courses for all grades. The programme started on 1 May 2021 with 18 colleagues from a range of underrepresented groups and from a variety of grades signed up to it. Aspire will be embedded into our core talent offer via the Academy.
Use data to challenge and check our progress on recruitment outcomes and pay and also review the CMA’s ethnicity pay gap	The current work on the ethnicity pay gap will provide a benchmark for comparison in future years. The development of the CMA’s Diversity Dashboard provides a valuable tool in collating and interrogating our data. Use of our Diversity Dashboard data will enable us to provide hiring managers with an overview of the composition of their directorate at the outset of a recruitment campaign. Coupled with analysis from other data sources we will also be able to better target our advertising to reach a diverse audience. We have reviewed our equality reporting practices in consultation with staff representatives in Q1 2021 to 2022. This review will ensure that we are carrying out analysis in a more statistically robust way and improve our ability to identify areas of concern in the outcomes for particular groups, including colleagues from ethnic minority backgrounds. This will also enable us to assess our progress towards meeting our equality commitments.
Creation of the Positive Action Steering Group (PASG)	The Positive Action Steering Group (PASG) has been set up and will ensure that we deliver on our Race Action Plan and continue to hold our Executive and Board to account. Erik Wilson, Chief Operating Officer and the Board’s race champion, leads this group and ensured that progress was made to deliver against each of our 4 stated commitments during 2020 to 2021.

For 2022 to 2023, our Race Action Plan will focus on the following:

Theme 1: Our Recruitment

Action 1: We will ensure that our recruitment methods and approaches are reviewed to provide the most diverse candidate pools for our campaigns. We will build our recruitment talent pool through identifying key specialists and targeting our networks.

Action 2: We will work on analysing our recruitment data to understand the diversity profile at key stages in the recruitment process.

Theme 2: Community Social Responsibility

The CMA Board and Executive are committed to eradicating inequalities in the CMA and championing the needs of colleagues from underrepresented groups. In our role within the public sector we want to ensure that we are visible in our leadership of driving race equalities across our professions.

Action 1: We will work with other key organisations across our professions to establish appropriate forums for discussion, learning and challenge so we can adopt improved practices to improve our diversity profile in the CMA.

Action 2: We will establish a set of specific actions to lead the development of a wide reaching community of practice, engaging with a variety of organisations and wider competition law specialists, with a focus on challenging traditional practice through events and distinguished speakers.

Action 3: We will ensure we promote our work through external media and communication campaigns to highlight our ambitions and achievements, which will include alumni outreach.

Theme 3: Embedding Practice Locally

The CMA Board and Executive want to ensure that there is a focus on race equality locally within directorates and teams, as well as driving improvements in key areas such as performance management.

Action 1: Building on the initiatives progressed by the CMA Staff Race Network we want to ensure that all teams consider developing and implementing their own local race action plan and take meaningful actions at a local level to ensure we are building diverse teams with the right opportunities to develop their careers.

Theme 4: Evaluate the effectiveness of our 2020 – 2021 plan and key initiatives

The CMA Board and Executive want to ensure that the steps we took in 2020 to 2021 have had positive impact, have been effectively embedded and will ensure lasting and tangible change at the CMA.

Action 1: We have established our Advisory Committee to better hear and represent those diverse voices at senior levels of decision making. We will ensure we enable and support our volunteer participants by providing them with ongoing key training and coaching support. We will evaluate the progress and maturity of our Advisory Committee to inform how this becomes embedded in our practice.

Action 2: We established our Accelerate Sponsorship Programme as our commitment to provide effective opportunities for talented colleagues to progress into senior roles. We will ensure this programme is evaluated in order for the Board and Executive to decide how this programme could become embedded into our core talent offer.

Declaration

The CMA confirms that all calculations have been carried out with all efforts made to ensure a robust and methodical approach to the production of our findings.

Footnotes

1. Ethnicity Pay Reporting, Government Consultation, BEIS, October 2018, page 12 ↩

2. The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 ↩

3. This is the headcount of staff deemed to be full pay relevant employees on the CMA payroll for gender pay gap reporting purposes. There were 891 staff employed by the CMA at this date, not all were full pay relevant employees and so are not included in the ethnicity pay gap report. ↩

4. Statistical Bulletin - Civil Service Statistics 2020, published August 2020 ↩

5. Statistical Bulletin - Civil Service Statistics 2020, published August 2020 ↩