Equality Impact Assessment (EIA): Stage 1: Initial Screening Form for
New/Revised Policies or Functions
A: Summary Details
Directorate: Resources
Section: Corporate HR
Person responsible for the assessment: Fiona Curran
Contact details: 0207 364 3107
Name of Policy to be assessed: Combating Discrimination and Harassment
Is this a new or revised policy: Existing
Date policy scheduled for Overview and Scrutiny/Cabinet/LAB:
B: Preparation
It is important to consider all available information that could help determine whether
the policy could have any potential adverse impact. Please attach examples of
available monitoring information, research and consultation reports.
1. Do you have monitoring data available on the number of people (from different
target groups) who are using or are potentially impacted upon by your policy? Please
specify what monitoring information you have available (your monitoring information
should be compared to the current available census data to see whether a
proportionate number of people are taking up your service).
The council aims to create an environment where all employees are treated with
respect. All discrimination and harassment complaints are taken seriously. If an
employee carries out such behaviour disciplinary action will be taken.
We have created a way for employees to report any discrimination and harassment
at work. Employees can use this procedure if they feel they have been:

Discriminated against because of race, sex, religion, sexual orientation or
disability
 Harassment
 Witnessed discrimination or harassment
Managers are responsible for implementing the policy.
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The Council currently monitors the impact of the Combating Discrimination and
Harassment procedure by monitoring each stage of the disciplinary process and the
outcome by all six equalities strands- ethnicity, age, disability, gender, sexual
orientation and religion and belief. The information available for analysis in this EQIA
is over 2008/2009 and represents a total of 16 CHAD cases.
2. If monitoring has NOT been undertaken, will it be done in the future or do you
have access to relevant monitoring data for this area? If not, specify the
arrangement you intend to make; if not please give a reason for your decision.
Not Applicable
3. Please list any consultations that you may have had and/or local/national
consultations, research or practical guidance that will assist you in completing
this EIA.
The current combating discrimination and harassment procedure is the result of
consultation with trade union representatives, CMT and Heads of HR
C: Your Policy or Function
1. What is the main purpose of the policy or function?
The main purpose of this policy is to create and maintain a working environment
where individuals are treated with dignity and respect. This procedure was created to
enable individuals to challenge unlawful discrimination and harassment in order to
achieve our commitments to oppose all forms of unlawful discrimination and
harassment.
2 Are there any other objectives of the policy or function, if so what are they?
Not applicable
3 Do any written procedures exist to enable delivery of this policy or function?
To assist in the fair and coherent application of this procedure across the Council the
following supporting tools have been developed to enable its effective delivery:


A managers’ guide to handling grievances
Employee Handbook
These documents supplement the Combating discrimination and Harassment
procedure to provide support and guidance to managers and employees.
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4 Are there elements of common practice in the service area or function that are
not clearly defined within the written procedures?
It is stated in the procedure that informal resolution is preferable to produce a speedy
resolution to the issue. As a result the individual may discuss their issue with their
line manager or HR representative on an informal basis before deciding their course
of action.
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


Who are the main stakeholders of the policy?
HR staff
Line Managers
LBTH employees
6 Is the policy associated with any other Council policy (s)?
The policy may be used in conjunction with the grievance resolution procedure and
the disciplinary procedure if appropriate.
7 Are there any areas of the service that are governed by discretionary powers? If
so, is there clear guidance as to how to exercise these?
The procedure aims to provide clear guidance on the informal and formal steps
which should be taken to address any complaints to ensure a fair and transparent
process. The application of the combating discrimination and harassment procedure
is managed by line managers (unless this individual is involved in the case) but
support and guidance is provided by the HR team who will coach and assist where
necessary.
The final decision on the outcome of this process rests with the investigating
manager, and will vary dependant on individual circumstances and the outcomes of
the investigation process. The investigation process is designed to enable line
managers to make a well-informed and impartial decision based on the facts
surrounding each individual case. The supporting framework, policy and guidance
couples with training provided to all investigating managers is aimed at ensuring fair
and equitable application of this procedure.
8 Is the responsibility for the proposed policy or function shared with another
department or authority or organisation? If so, what responsibility, and which
bodies?
Although the outcome decision rests with the Investigating Manager in that particular
area, the investigation process should be far-reaching and may involve a number of
other departments within the Council, including:
 HR Function
 Occupational Health
 The individual’s directorate, manager and team members where appropriate,
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D: The Impact
Assess the potential impact that the policy could have on each of the target groups. The potential impact could be negative, positive or
neutral. If you have assessed negative potential impact for any of the target groups you will need to also assess whether that negative
potential impact is high, medium or low – see glossary in the attached guidance notes for definitions.
1.
a) Identify the potential impact of the policy on men and women:
Gender
Women
Men
Positive
Negative (please
specify if High,
Medium or Low)
Neutral
Reason
Neutral
In 2008/2009 the gender breakdown of
the workforce was 60% female and 40%
male.
Neutral
58% of complaints received in this time
period were from female employees, of
these 7% were upheld, 60% were not
upheld, 20% were ongoing
42% of complaints received in this time
period were from male employees. 82%
of these were not upheld, and 18% are
ongoing.
b) Identify the potential impact of the policy on different race groups:
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Race
Positive
Negative (please
specify if High,
Medium or Low)
Asian (including
Neutral
Reason
Neutral
In 2008/2009 Asian workers represented
25.4% of the Council’s workforce. This
group raised 19% of all complaints, of
these complaints, 17% were upheld, 67%
were not upheld, and 17% were ongoing.
Bangladeshi, Pakistani, Indian,
Chinese, Vietnamese, Other
Asian Background – please
specify________________)
Black (including Caribbean,
low
In 2008/2009 Black employees
represented 6% of the workforce. This
group raised 22% of all complaints, of
these 89% were not upheld and 11%
were upheld.
Somali, Other African, Other
black background – please
specify_____________)
White (including English,
Neutral
Scottish, Welsh, Irish, Other
white background – please
specify_________________)
Mixed Dual heritage
Neutral
(White and Black Caribbean,
White and Black African, White
and Asian, Other mixed
background - please
specify__________________)
Other (please specify)
Neutral
In 2007/2008 this group raised 10% of all
complaints, of these 80% were not
upheld, 10% were withdrawn and 10%
were ongoing.
In 2008/2009 White workers made up
40.3% of the workforce. This group raised
22% of complaints, of these 44% were not
upheld, 44% were ongoing and 11% were
withdrawn.
In 2008/2009 workers from a mixed or
dual heritage made up 1.8% of the
workforce. This group raised 2% of all
complaints, none of which were upheld.
17.7% of our workforce have stated their
ethnicity as ‘other’. There were no
complaints raised by this group.
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c) Identify the potential impact of the policy on disabled people:
Disability
Positive
Negative (please
specify if High,
Medium or Low)
Reason
The data available around the proportion of
disabled employees within the council must be
qualified by the fact that in 2008/2009 9.4% of
employees declined to state if they had a
disability and no data was held on 41% of
employees. In addition, 12% of employees
involved in the complaints procedure declined
to state if they had a disability. Of these, 67%
were not upheld, and 33% were withdrawn.
Disabled
Not Disabled
In 2008/2009 2.6% of the workforce had
declared themselves as disabled. This group
raised 15% of all complaints in the time period,
50% of which were not upheld, 25% were
ongoing and 25% were withdrawn.
low
Neutral
In 2008/2009 46.2% of employees stated that
they were not disabled. This group raised 73%
of all complaints, of these 5% were upheld,
74% were not upheld and 21% were ongoing.
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d) Identify the potential impact of the policy on different age groups:
Age Group (specify,
for example younger,
older etc)
Positive
Negative (please
specify if High,
Medium or Low)
Neutral
Reason
In 2008/2009 the workforce make-up by age
showed that 7.3% of workers were 24 or under;
52% were 25- 44; 26.2% were 45- 54; 11.37%
were 55- 62; and 2.6% were 62 or older.
Younger
( under 30)
Neutral
Neutral
Middle-Aged
(30-50)
Neutral
Older
(51 and older)
Neutral
Workers aged 20-30 raised 12% of all
complaints, of these 67% were not upheld, and
33% were ongoing.
Workers aged 31-40 raised 31% of all
complaints, of these 13% were upheld, 50%
were not upheld, 25% were ongoing and 13%
were withdrawn.
Workers aged 41-50 raised 42% of all
complaints, of these 91% were not upheld, 9%
were ongoing.
Workers aged 51-60 raised 15% of all
complaints, of these 50% were not upheld,
25% were ongoing and 25% were withdrawn.
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e) Identify the potential impact of the policy on lesbian, gay men, bisexual or heterosexual people:
Sexual Orientation
Positive
Negative (please
specify if High,
Medium or Low)
Neutral
Reason
In 2008/2009 data available on sexual
orientation across the council does not capture
the breakdown of the workforce effectively as
14.2% of employees declined to state their
orientation, and no data on this is held for
22.2% of employees. In addition, 31% of all
employees in this process declined to state
their orientation, of these 63% were not upheld,
25% are ongoing and 13% were withdrawn.
Lesbian
Neutral
Gay Men
Neutral
Bisexual
Neutral
Heterosexual
Neutral
In 2008/2009 0.6% of employees in the Council
defined their orientation as Lesbian. These
employees raised 4% of all complaints, of
these none were upheld.
In 2008/2009 1.2% of employees declared their
orientation as gay. These employees raised
4% of all complaints, of these none were
upheld.
In 2008/2009 bisexual employees represented
1.2% of employees in the workforce There
were no complaints on record for this group.
In 2008/2009 heterosexual employees
represented 60.5% of the workforce. This
group raised 62% of complaints, 6% of these
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were upheld, 75% were not upheld, 13% were
ongoing, and 6% were withdrawn.
f) Identify the potential impact the policy on different religious/faith groups?
Religious/Faith
groups (specify)
Positive
Negative (please
specify if High,
Medium or Low)
Neutral
Reason
The information available in this area is
impacted upon by the fact that 9% of
employees in the Council declined to state their
religion, and no data is held on 21.1% of
employees. In addition, 42% of all employees
lodging a complaint did not state their
religion/belief.
Buddhist
Neutral
Christian
Neutral
Hindu
Neutral
Jewish
Neutral
Muslim
Neutral
In 2008/2009 Buddhist employees made up
0.6% of the workforce, they lodged 4% of all
complaints. Of these complaints, all were
upheld.
In 2008/2009 this group represented 32.6% of
the workforce. This group lodged 27% of all
complaints, of these 86% were not upheld and
14% were ongoing.
In 2008/2009 this group made up 1.1% of the
workforce. There were no complaints made
from employees in this group.
In 2008/2009 this group made up 0.6% of the
workforce. There were no complaints made
from employees in this group.
In 2008/2009 this group represented 17.6% of
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Sikh
Neutral
Other (please specify)
Neutral
the workforce. This group made 23% of
complaints, of these 83% were not upheld, and
17% were ongoing.
In 2008/2009 this group made up 0.7% of the
workforce. There were no complaints made
from employees in this group.
In 2008/2009 11% of the workforce stated that
they had no religion and 5.4% defined their
religion as ‘other’. Employees in this group
raised 4% of all complaints, of these, 64% were
not upheld, 18% were ongoing and 18% were
withdrawn.
g) As a result of completing Question 1 a-f above what is the potential impact of your policy?
High 
Medium

Low

If you have assessed the potential impact as HIGH you must complete a full potential impact assessment.
2. Could you minimise or remove any negative potential impact that is of medium or low significance? Explain How.
This policy is designed to incorporate all the requirements of Equalities legislation and to promote parity of treatment by providing clear
standards of acceptable behaviours and an open and transparent process for both managers and employees.
Race: Full analysis into any differing impact of this policy on race groups will be undertaken in the 2008-2010 Equalities Report and any
required actions will be proposed. It is evident that black employees raised a proportionately higher percentage of complaints then that
representation in the workforce. This will be analysed in more detail in the Equalities report.
Gender: There was no negative effect apparent in the information available
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Disability: analysis of the information available showed that disabled employees raised a proportionately higher percentage of complaints
then their representation in the workforce. This will be examined in more detail in the Equalities report. The validity of the data available was
however impacted upon by the lack of responses to disability monitoring across the council and lack of information on a large proportion of
employees. Further monitoring of disability would therefore benefit employees in monitoring the impact of policies and procedures.
Age: There was no negative effect apparent in the information available
Sexual Orientation: There was no negative effect apparent in the information available. However large proportions of the employees lodging
complaints did not state their orientation which will impact on the validity of this data.
Religious/Faith groups: There was no negative effect apparent in the information available. Large numbers of employee in the workforce
also declined to state their religious beliefs which impacted on the validity of data. Further monitoring of this data would therefore benefit the
monitoring of the impact policies and procedures have on this group.
Please ensure that all actions identified are included in the attached action plan and in your service plan.
Please sign and date this form, keep one copy and send one to Equalities Team..
Signed
Lead Officer
Date
Signed
Service Head
Date
Signed
Strategy and Programmes
Date
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Action Plan
Recommendation
Key activity
Progress milestones
Officer
Responsible
Progress
Data analysis
Further detailed analysis of the
impact of the Combating
discrimination and harassment
process on equalities groups in the
Equalities Report. This will ensure
that recommendations are based on
detailed analysis and on findings
over time rather than a single years
data.
Ensure that managers and HR are
fully aware of the procedure and
how to apply it within their teams
Completion of the 2008-2010
Equalities report
Corporate HR
Draft Report
Presented to
CESG April
2010,
currently
redrafting
Ensure that employees and
managers are aware of the
procedure and how it applies to their
role.
Increase the reliability and volume of
data available on all equalities
strands, particularly disability,
orientation and religion/belief, where
large proportions of the workforce
have declined to state their status or
we hold no information on them.
Consistent application and
outcomes for all employees
within the council.
Directorate HR
Completion of Staff Equalities
Audit.
Corporate HR
Training
Communication
Data Monitoring
Consistent application by
HR
managers and outcomes for all Directorates
employees within the council.
and OD
Consultation
with forums
underway,
form
designed
and IT to
update on
capability.
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