Equality information report and ethnicity pay gap report 2021-2022 (accessible version)
Updated 31 March 2023
Applies to England
© Crown copyright 2023
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1. Introduction
1.1 The Regulator of Social Housing as a public body with more than 150 employees[footnote 1], is required to publish relevant, proportionate equality information to demonstrate compliance with the Equality Duty and to promote transparency and accountability for our equality performance.
1.2 The information contained within this report has been compiled to comply with the specific duty to publish, and demonstrates due regard to the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relationships between people who share a protected characteristic and those who do not.
1.3 It covers:
- our staff, including equality and diversity data about our staff
- those affected by our policies and procedures
- the annual review of progress against our equality objectives.
1.4 The information within this report covers the year ending 31 March 2022.
1.5 While we believe it is important to be as transparent as we can on these matters, as a relatively small organisation with around 200 employees, there may be circumstances where we cannot publish all our diversity information to ensure we preserve the anonymity of staff.
1.6 In this report, in addition to the information relevant to our specific duty to publish, we have also chosen to publish findings of a review of our ethnicity pay gap at 31 March 2022. These findings are published on a purely voluntary basis as we believe it is good practice and transparent to fully support the regulations regarding equal pay across the public sector. This information is presented in a similar format to that for gender pay gap reporting.
2. Our staff
2.1 One of RSH’s core values is that “We embrace diversity and seek to be an inclusive and supportive organisation”.
2.2 In 2022-23 we refreshed our Equality diversity and inclusion strategy and action plan which focuses on recruitment, staff engagement, staff development and embedding good practice. Actions have progressed and we will be reviewing the plan in 2023/24, taking into account feedback from our planned 2023 staff survey.
2.3 Our focus in the coming year is to continue to build on the strong foundations we have laid. We have been clear that one of the main areas we need to address is increased ethnic minority representation at senior levels in the organisation. We will continue to focus on recruitment and development of existing staff to seek to improve ethnic diversity at senior levels, where opportunities arise through expansion or staff turnover. We will also continue to develop our EDI capacity and capability, learning from other organisations, and providing different channels for feedback and engagement for our staff, and to help identify any further actions we can take.
2.4 The delivery of our EDI strategy and action plan is fully supported by both the Board and the Executive, who review progress on a regular basis, and who have appointed individuals to provide an equalities challenge function. We also have a Senior Leadership Team EDI steering group which supports the delivery of the action plan, as well as a Women’s Network and a Black, Asian and Minority Ethnic network. To supplement these groups in 2022/23 we introduced a staff EDI Sounding Board and an advisory group of staff with disabilities.
Diversity profile
2.5 The data below summarises our workforce diversity profile as at 31 March 2022 with comparative data for the previous two years.
2.6 In some cases, staff have either not completed the relevant sections or have declined to provide the data, referenced above as ‘Declined to respond/ undeclared’. We take diversity monitoring seriously and continue to encourage staff to update their information to ensure that our analysis remains relevant.
2.7 Most of the changes are small and relate to natural variation from staff turnover in a small organisation. One change worth noting is in the proportion of ethnic minority staff. We have low turnover but increased headcount by 8% between 2021 and 2022. Of the net increase in headcount, 41% identify as from an ethnic minority.
RSH diversity profile as at 31 March 2022[footnote 2]
| Characteristic | Percentage of staff | Change from 2021 to 2022 | ||
|---|---|---|---|---|
| March 2022 | March 2021 | March 2020 | ||
| Ethnicity | ||||
| Ethnic minority | 18% | 16% | 16% | 2% |
| White | 80% | 82% | 82% | -2% |
| Declined to respond/ undeclared | 2% | 2% | 2% | - |
| Gender | ||||
| Male | 37% | 37% | 37% | - |
| Female | 63% | 63% | 63% | - |
| Sexual orientation | ||||
| Lesbian/ gay/ bisexual | 7% | 6% | 7% | 1% |
| Heterosexual | 82% | 82% | 78% | - |
| Declined to respond/ undeclared | 11% | 13% | 15% | -2% |
| Working pattern | ||||
| Full time | 94% | 94% | 95% | - |
| Part-time | 6% | 6% | 5% | - |
| Age | ||||
| 55-64 | 22% | 23% | 24% | -1% |
| 45-54 | 32% | 34% | 35% | -2% |
| 35-44 | 27% | 27% | 25% | - |
| 25-34 | 18% | 16% | 14% | 2% |
| Under 25 | 0% | 1% | 1% | -1% |
| Disability | ||||
| Declared disabled | 9% | 9% | 8% | - |
| Declared non-disabled | 85% | 85% | 43% | - |
| Declined to respond/ undeclared | 7% | 6% | 48% | 1% |
2.8 The table below provides a further breakdown for 2022 of these characteristics by staff grade. As shown in the table, and as demonstrated in the analysis of the ethnicity pay gap later in this report there is a lack of ethnic diversity in senior management. There is good level of diversity in relation to other characteristics. Increasing the ethnic diversity of senior management is a priority for the organisation.
| Characteristic | Senior management | All other staff | ||||
|---|---|---|---|---|---|---|
| March 2022 | March 2021 | Change | March 2022 | March 2021 | Change | |
| Ethnicity | ||||||
| Ethnic minority | 1% | 0% | 1% | 26% | 26% | - |
| White | 96% | 97% | -1% | 72% | 72% | - |
| Declined to respond/ undeclared | 3% | 3% | - | 2% | 2% | - |
| Gender | ||||||
| Male | 49% | 48% | 1% | 30% | 31% | -1% |
| Female | 51% | 52% | -1% | 70% | 69% | 1% |
| Sexual orientation | ||||||
| Lesbian/ gay/ bisexual | 12% | 11% | 1% | 5% | 3% | 2% |
| Heterosexual | 73% | 73% | - | 86% | 87% | -1% |
| Declined to respond/ undeclared | 15% | 16% | -1% | 9% | 10% | -1% |
| Working pattern | ||||||
| Full time | 96% | 95% | 1% | 94% | 92% | 2% |
| Part-time | 4% | 5% | -1% | 6% | 8% | -2% |
| Age | ||||||
| 55-64 | 21% | 23% | -2% | 23% | 26% | -3% |
| 45-54 | 37% | 36% | 1% | 30% | 30% | - |
| 35-44 | 36% | 36% | - | 23% | 23% | - |
| 25-34 | 6% | 5% | 1% | 24% | 20% | 4% |
| Under 25 | 0% | 0% | - | 0% | 1% | -1% |
| Disability | ||||||
| Declared disabled | 15% | 16% | -1% | 5% | 5% | - |
| Declared non-disabled | 79% | 78% | 1% | 88% | 89% | -1% |
| Declined to respond/ undeclared | 6% | 6% | - | 7% | 6% | 1% |
Recruitment
2.9 We encourage applications from a diverse range of candidates and carry out anonymised shortlisting.
2.10 Where possible we take positive action. We keep under review where we advertise vacancies, including use of a number of specialist job sites. We have operated anonymised shortlisting in recruitment for some time but have taken further positive action. We have for some time offered a guaranteed interview for candidates with a disability that meet the benchmark requirements for the role. We have further looked to achieve a minimum of 20% ethnic minority candidates on recruitment shortlists, where we have sufficient candidates who have reached the required benchmark for the role. This further action was introduced in late 2020. As set out in the previous section there was a significant increase in the proportion of new recruits who are from an ethnic minority between 2021 and 2022.
Employee engagement
2.11 We currently carry out our staff survey every two years with the next one due in the 2023/24 financial year. In our previous survey, in July 2021, our results were strong with the majority of ratings at or above the relevant public sector and Civil Service benchmarks as well as improving on our previous set of results.
3. Equality for those affected by our policies and practices
3.1 This section details how we meet our duty to those who are affected by our policies and practices, or who engage with us in relation to the exercise of our regulatory function.
3.2 The following sections provide a narrative summary of our approach to ensuring we have due regard to the aims of the duty in decision-making with regard to registration decisions; equality impact assessments on statutory consultations; the consumer regulation panel; and decisions made by the Regulation Executive Group and Board.
Registration decisions
3.3 There are two stages to RSH’s application process for registering an organisation as a registered provider; during the second (detailed) application stage, applicants are asked to provide assurance on their compliance with the Equality Act 2010.
3.4 In particular, RSH asks whether applicants have any, or intend to have any, restrictions of services in place regarding persons sharing a relevant protected characteristic. Where RSH establishes that such restrictions are in place, or will be put in place, it asks the applicant for specific assurance on how it has satisfied itself that it is acting lawfully under the current equality legislation.
Consultations
3.5 As a public body, we are required to consult on any proposed changes to our regulatory approach. As part of the consultation process, we ensure that we consider our duties under the Equality Act 2010.
3.6 Equalities requirements are considered at relevant stages of the drafting process when we are developing new regulatory standards and approaches. Where issues are identified, these are specifically set out in reports to both REG and the Board, to enable appropriate consideration at relevant stages of the decision-making process.
3.7 As part of the consultation we normally include a specific question to respondents on their agreement with and understanding of the equalities analysis we have undertaken, and we invite comment and recommendations for further consideration should it be felt we have missed anything relevant of note.
3.8 Following the end of the formal consultation period we analyse the feedback on our equality analysis and where appropriate to do so, propose revisions in light of the feedback. We then report the results of the consultation to our Executive Group and Board and specifically highlight any feedback we receive with equalities implications.
3.9 Following approval, we formally report the results of the consultation publicly via a Decision Statement which both explores the feedback we received on the equality analysis but also includes the updated analysis. Where appropriate, and based on feedback, we may make reasonable adjustments in relation to the issue under consultation.
Regulatory referrals
3.10 RSH has due regard to its equality duties in carrying out its consumer regulation work and will seek to make reasonable adjustments for individuals contacting RSH where appropriate. For example: providing correspondence in large print, taking details of complaints over the telephone (where an individual has difficulty with written forms of communication), and arranging translations of key documents and our correspondence (e.g. into Braille).
3.11 Where we receive individual referrals that suggest a registered provider may not have taken tenants’ needs into account (in respect of a protected characteristic), we have due regard to our equality duties through our consumer regulation processes.
3.12 Where appropriate, we signpost the individual to services who may be able to assist, including the Equalities and Human Rights Commission and the Housing Ombudsman Service.
Regulation Executive Group and Board decisions
3.13 The Executive Group and Board consider operational and strategic matters brought before them through the submission of formal papers. The Executive Group and Board each have members specifically charged to challenge the equality and diversity impact of organisational decisions.
3.14 Both Executive and Board papers include a section on equality and diversity implications, within which the author should demonstrate how RSH has given due regard to the Equality Duty in the consideration of proposals.
3.15 This enables appropriate consideration at the relevant stages of the decision-making process. We have developed guidance and training for staff to help them integrate thinking on equality and diversity into the development of policies and operational delivery.
4. Annual review of equality objectives
4.1 The Equality Act 2010 requires all public bodies to publish equality objectives it thinks it should achieve to meet the general Equality Duty (sometimes called the Public Service Equality Duty). The general Equality Duty says that public bodies must, in the exercise of their functions, have due regard to the need to:
i. eliminate discrimination, harassment, and victimisation
ii. advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it
iii. foster good relations between persons who share a relevant protected characteristic and persons who do not share it.
4.2 We published our first set of equality objectives in July 2020 following a statutory consultation between January and March 2020.
4.3 In preparing the objectives we were mindful of:
i. our statutory obligation to be proportionate and not to inappropriately increase the regulatory burden, and our co-regulatory approach to regulation
ii. the applicability of our general Equality Duty in our day to day work.
4.4 We considered it most appropriate for our first equalities objectives to focus on areas where we can have the most immediate impact, namely:
i. points where we interact with tenants (objectives 1 and 2)
ii. the organisational culture we create (objective 3).
4.5 When we published our objectives, we said that we will review them within the mandatory four-year period, and we will also keep these under review if our role changes or if we identify further areas which would benefit from setting equality objectives.
4.6 The table below updates on our equality objectives following the second year of delivery. We have made good progress across the deliverables with many of them now being embedded into business as usual. Given this, our commitment to review the objectives within the mandatory four-year period, and the upcoming change in our consumer regulation remit, we have worked on updating our equality objectives. We will publish a new set of equality objectives, following a consultation in 2023/24.
| Objective | Delivered through | Year 2 update |
|---|---|---|
| Ensure that where equality and diversity concerns are raised through our enquiries process, they are considered in line with our statutory objectives | i. Appropriate training for our enquiries team and staff who regularly handle complaints | We provide specialised training, including refresher courses as needed, to our enquiries team and other staff who regularly handle complaints. This focuses primarily on mental health and learning disabilities. We also have in-house guidance on and ran workshops to help teams understand how to comply with the Public Sector Equality Duty. |
| ii. Ensuring that complaint referrals identified as having an EDI dimension are recorded as such and dealt with in accordance with our consumer regulation guidance | We collect EDI information where appropriate in our case management system when we log referrals. All referrals are dealt with in accordance with our guidance. | |
| iii. We intend to highlight key lessons learned and good practice from discrimination cases and enquiries in our annual report on consumer regulation | We will identify lessons learned and good practice where relevant in our annual consumer regulation reviews. There were no specific points to be raised in the 2022 review. | |
| iv. Investigating technological solutions to improve collation and analysis of EDI data arising from enquiries | We updated our case management system to improve the consistency of the data we collect by allowing users to select from a pre-defined list of EDI issues. This has streamlined the analysis of this data. | |
| The Regulator will review its methods of communicating to ensure that it does so in an inclusive way | i. Training for staff on accessible communication skills (particularly around mental health and learning disabilities) | We provide periodic training focusing on communication with people with mental health issues and learning disabilities for our externally facing colleagues. We also offer an effective writing course for all colleagues which includes guidance on Plain English, how to write in an easily understood way, and what to consider when drafting documents for external publication to make them accessible. |
| ii. Ensuring that the regulator’s publications are as accessible as is reasonable, in line with our duty to make reasonable adjustments | We have reviewed our publications and our pages on Gov.uk to make sure that these are as accessible as is possible. | |
| iii. Ensuring that our communications, such as responses to enquiries, meet the individual’s communication needs where reasonable in line with our duty to make reasonable adjustments | We draft and review all our responses to enquiries according to the information we have about our correspondents’ communication needs. We make reasonable adjustments when these are requested. | |
| iv. Proactively engaging with Government Digital Services about what changes can be made to our website to make it as accessible as possible | We have completed this and made changes in line with the guidance we received. All further and ongoing changes to our content will be made in line with accessibility requirements and guidance. | |
| We will provide a supportive and inclusive working environment for all | i. Collating data on gender pay to establish our gender pay gap. Data to be collected and published in accordance with the regulator’s People Strategy | We collect, analyse and publish data on both the gender and ethnicity pay gaps. The reports are available on our website. |
| ii. Improving the collation of equality and diversity data in order to identify barriers to underrepresented groups to recruitment and progression, advance equality of opportunity, and foster good relations amongst all groups within the regulator’s workforce | We report recruitment data to REG on a monthly basis. We have also implemented positive action in recruitment shortlisting. We have an EDI Sounding Board as well as various staff networks and working groups in place which provide support to colleagues. We also work closely with the unions for staff benefit. | |
| iii. Establishing a robust baseline and using data to inform how the regulator embeds equality and diversity into its approach to developing policies and/ or strategies for staff to support continuous improvement | We developed an internal EDI strategy and action plan in early 2021/22 following consultation with unions, staff networks and working groups, and refreshed it for 2022/23. We have built success measures based on staff survey indicators and organisational HR data to develop a baseline against which to monitor progress. | |
| iv. Using data to review how effective the policies we have in place are at delivering the desired outcomes | We have developed and implemented a template and guidance on carrying out of Equalities Impact Assessments, so we have a consistent approach to evaluating the impact of our work. Training on the new tools was rolled out in January 2023. | |
| v. Carrying out learning and development activity to further foster an inclusive working environment including mandatory training on unconscious bias, discrimination, harassment and equality legislation for all staff | Most staff completed online training provided for the wider Civil Service on unconscious bias and EDI in 2020/21. In response to Government Campus discontinuing a number of its EDI modules, we have been looking into alternative delivery options for the regulator. We are piloting further training available from Government Campus. | |
| vi. Actively promoting equality, diversity and inclusion in the workplace | We developed an internal EDI strategy and action plan in early 2021/22 following consultation with unions, staff networks and working groups, and refreshed it for 2022/23. We have guidelines in place and support the creation of staff-led networks. We have an active Women’s Network and BAME Network. We keep our approach under regular review and have merged our Positive Working Group and EDI steering group into a new EDI Sounding Board which will be better able to support the delivery of our EDI objectives and increase diversity, inclusion and staff wellbeing. |
5. Ethnicity pay gap
5.1 There is no statutory requirement for any organisation to report its ethnicity pay gap, but we believe that it is best practice to be open and transparent to fully support RSH’s approach in ensuring that we offer a diverse and inclusive workplace for all staff, present and future. As there is no defined format for an ethnicity pay gap report, currently, we have chosen to adopt a common approach to that prescribed for presenting the gender pay gap.
Ethnicity pay gap analysis
5.2 Our figures at 31 March 2022, together with comparatives for the preceding two years are as follows:
| 2022 | 2021 | 2020 | 2021-2022 difference % | |
|---|---|---|---|---|
| Mean pay gap [footnote 3] | 20.3% | 20.1% | 20.3% | 0.2% |
| Median pay gap [footnote 4] | 18.7% | 20.2% | 16.8% | -1.5% |
5.3 The ethnicity pay gap is measured in terms of the differential between the mean and median average hourly pay received by white and ethnic minority staff. It is not a measure of pay equality for equivalent roles. The comparison of mean and median pay in RSH ethnicity shows a gap in favour of white staff.
5.4 The mean pay gap shows a slight increase of 0.2% compared to 2021 figures. The median pay gap has decreased by 1.5% in favour of white employees. Due to our small workforce, the median pay gap can be affected by very small changes in our workforce.
5.5 The pay gap is a reflection of the differing demographic profile of staff at different role levels in the organisation. Looking at this in terms of the proportion of white and ethnic minority employees at RSH in each pay quartile it is evident that the low levels of ethnic minority representation in the upper pay quartiles is the driver for the pay gap.
| 2022 | 2021 | 2020 | 2021-2022 difference % | ||||
|---|---|---|---|---|---|---|---|
| Pay quartile | White % | BAME % | White % | BAME % | White % | BAME % | |
| Top | 97.8% | 2.2% | 97.7% | 2.3% | 97.5% | 2.5% | -0.1% |
| Upper middle | 78.3% | 21.7% | 84.1% | 15.9% | 82.1% | 17.9% | 5.8% |
| Lower middle | 89.4% | 10.6% | 79.5% | 20.5% | 80.0% | 20.0% | -9.9% |
| Bottom | 66.0% | 34.0% | 74.4% | 25.6% | 77.5% | 22.5% | 8.4% |
| Total | 82.8% | 17.2% | 84.0% | 16.0% | 84.3% | 15.7% | 1.2% |
5.6 We have seen an increase in ethnic minority representation in the upper middle quartile, but the organisation is not as diverse at more senior levels as we wish it to be and we continue to take steps to support increased diversity in recruitment are discussed earlier in this report.
5.7 RSH operates a modest annual bonus pay scheme on a fixed scale, with awards based on individual staff performance in their role. During the year, bonuses were paid at set values of:
- £0 where individual performance does not meet expectations
- £275 where performance meets expectations, and
- £575 where performance exceeds expectations.
5.8 Bonuses are awarded irrespective of any protected characteristic and are moderated across the organisation to ensure consistency. To be considered for a bonus, staff must first have successfully completed their six-month probationary period following joining the organisation.
5.9 The mean bonus pay gap was 1.4% in favour of ethnic minority employees compared to 1.1% in favour of white employees in 2021 and 21.2% in favour of white employees in 2020. This does not reflect any change in the bonus scheme but highlights how sensitive the figures can be to changes in the number of higher-level bonus paid to ethnic minority and white staff from year to year.
5.10 The median bonus gap is unchanged between 2022 and 2021 at 0.0%.
Action plan
5.11 RSH is fully committed to the principle of equality, diversity and equal treatment for all its employees, regardless of any characteristic. We offer a very flexible employment package with the opportunity to work full or part time, and flexibility on work locations. We will also consider variations in working patterns where practicable. We believe this assists equality and opportunity, but we continue to look to identify and address, where possible, any further barriers to recruitment or progression.
5.12 Ethnic minority staff are significantly underrepresented in the senior management of the organisation. The organisation has recognised the need for positive action and additional measures put in place to support diversity in recruitment are discussed earlier in this report. Specific members of our Board and Executive team hold an equalities challenge role to support the implementation of actions on diversity and inclusion across the organisation. We continue to engage with staff to test the effectiveness of our actions plans, adapting them where necessary.
5.13 We continue staff development to ensure that all our staff who want to progress are equally equipped to take opportunities for advancement when they arise and continue to work with the internal BAME network to identify further active steps we can take to support an ethnically representative and inclusive workforce at all levels.