Guidance for meeting equality, diversity and inclusion (EDI) funding conditions
The Affordable Homes Programme 2021-26 introduces requirements on partners to advance equality, diversity and inclusion (EDI) in their own organisations and in the wider sector as a condition of receipt of funding from the GLA.
The Mayor has welcomed the response of the sector as it works towards demonstrating compliance with the funding conditions. The GLA has produced a guide which captures the wide array of good practices in EDI being delivered by partners. The good practice guide should be read alongside the Affordable Homes Programme 2021-26 Funding Guidance and seeks to aid partners in considering how they could meet these existing requirements.
Read our Sharing good practice in Equality, Diversity and Inclusion guidance.
Principles
The introduction of the funding conditions supports the Mayor’s commitment to supporting increased diversity in the built environment sector. He expects partners to contribute to his vision of a more equal, diverse and inclusive London by meaningfully enhancing their organisational practices, procurement methods and engagement with communities.
In meeting the requirements, the ambition is for organisations to
- be encouraged to reflect and act on their own approach to EDI
- effect lasting culture change throughout organisations
- embedding EDI in how homes are developed and delivered.
This can help to ensure that the homes delivered through the programme meet the needs of London’s diverse communities.
There are three key principles that the GLA is seeking to embed:
- Embedding culture change
Considering the EDI impacts of our work and how to pro-actively advance EDI should become a ‘golden thread’ embedded throughout organisations, and a responsibility of all employees. EDI should not be relegated to one individual or the remit solely of external consultants and should be supported at all levels, including management and governance. - Advancing EDI is an ongoing process
Considering the EDI impacts of our work and pro-actively advancing EDI both within organisations and in how homes are delivered should be a continuous and ongoing process. Training and data collection need to be conducted regularly and result in behaviour change and improved practices. EDI needs to be embedded throughout the lifetime of a housing development project, from inception, design, planning and construction. It is not enough to tick a box or look at EDI impacts at the completion of a development. - Recognising intersectionality and a broad understanding of diversity
Intersectionality requires us to consider how people’s characteristics combine to affect their experiences. It is important to look beyond the definitions of protected characteristics and be able to look at EDI through the lens of intersectionality, wider elements such as socio-economic status, care responsibilities, and ensuring mental health is included when looking at disability. As well as to recognise and engage with the many forms of community that may exist and co-exist, including communities of location and identity.
Requirements
As set out in the Homes for Londoners: Affordable Homes Programme 2021-26 Funding Guidance, partners will be contractually required to meet two requirements within a year of their grant allocation being confirmed:
- Five minimum equality, diversity and inclusion standards.
- To produce and publish an Equality, Diversity and Inclusion Action Plan for their organisation.
All partners must meet five minimum standards:
- All investment partners must offer equality, diversity and inclusion training for all employees.
- All investment partners must implement a zero-tolerance approach to all forms of discrimination, harassment and bullying.
- All investment partners must broaden recruitment channels and encourage applications from diverse and under-represented groups.
- All investment partners must collect and monitor workforce data to benchmark the diversity of their workforce against the to the London benchmark.
- All investment partners must publish their gender and ethnicity pay gaps.
Smaller organisations with fewer than 250 employees are exempt from standards four and five if this would risk breaching the privacy of individual employees.
However, all organisations are encouraged to meet the requirements wherever possible. The GLA’s Workforce Equality Data Guide includes guidance for SMEs on how to collect and monitor workforce data, taking into account the particular challenges for SMEs (these are also linked to in the Resources section below).
All larger organisations (above 250 employees) are encouraged to gain full accreditation under the Mayor’s Good Work Standard (GWS). GWS sets the benchmark the Mayor wants every London employer to work towards and achieve, and brings together best employment practice and links to resources and support from across London to help employers improve their organisations.
The initiative has been developed in collaboration with London's employers, professional bodies and experts. Organisations able to meet the GWS criteria can apply for accreditation and recognition as leading employers from the Mayor. The GLA will not intervene in individual complaints against organisations regarding compliance with the requirements.
Guidance for implementing the minimum standards
The standards seek to implement the Mayor's Good Work Standard ‘diversity and recruitment’ pillar and are being introduced to reflect the Mayor’s commitment to ensuring London is a more equal, diverse and inclusive city for all.
The standards are intended to ensure a minimum baseline position across organisations in terms of basic good practice in relation to EDI. Many organisations may well already be delivering on these fully, while others will need to expand existing approaches, or introduce new measures in order to comply. The GLA encourages organisations to go beyond these minimum standards in their efforts to advance EDI in their own organisations, particularly for organisations which already have well-developed approaches.
The minimum standards must be met within twelve months from allocation of funding, and from then on updated on an annual basis. The GLA will discuss compliance with standards at programme quarterly review meetings with delivery partners. For example, workforce data and gender and ethnicity pay gaps should be updated annually. Meanwhile, providing EDI training, implementing a zero-tolerance approach to all forms of discrimination, bullying and harassment, and broadening recruitment channels, should be ongoing practices.
Meeting the standards is not an end in itself when it comes to advancing EDI. The GLA encourages partners to think about the wider outcomes that can be supported by meeting the requirements set out above. Data collection in particular should be seen as a first step towards making informed decisions about how to change and improve organisational practices in order to meet objectives of a more equal, diverse and inclusive workforce.
Meanwhile, EDI training offered to employees should be meaningful and require participation and engagement from participants. To do so, it should be provided on an ongoing basis throughout the year, and with training broad enough to capture specifics around issues for specific groups, communities or protected characteristics, for example.
Partners are also required to develop, publish and implement an EDI Action Plan. These plans must include a minimum of one action or initiative for each of the following three themes:
- Organisational equality, diversity and fairness.
- Sustainable and diverse supply chains.
- Working together with Londoners.
Guidance for implementing the Action Plans
EDI Actions Plans must be public documents and available online. They should provide a vision for change, rationale for implementing the actions or initiatives set out, and timeframe for implementation. The ambition is for the Action Plans to provide a roadmap for organisations to develop and improve their approach to EDI across, but not limited to, the three themes listed above.
It is expected that for many organisations the requirement to produce an action plan will build on work already underway and in some cases, existing action plans. Where this is the case, partners must ensure that their Action Plan meets the requirements of the AHP Funding Guidance, even where this draws heavily on existing documents or work.
The GLA has deliberately not taken a prescriptive approach and instead supports organisations to decide which actions or initiatives are the most appropriate and relevant for them to deliver on across, but not limited to, the three themes. Find a non-exhaustive list of indicative actions that might be considered.
Theme 1 guidance: Organisational equality, diversity and fairness
Actions under this theme should support long-lasting and meaningful organisational change that advance equality, diversity and inclusion of organisations in the housing sector.
This includes: promoting best practice in employment by ensuring workers are treated and paid fairly; ensuring equal access to development opportunities and that all staff are supported to achieve their full potential; tackling discrimination and bias, and advancing equality, diversity and inclusion to make every employee feel valued.
Theme 2: Sustainable and diverse supply chains
Actions under this theme should support both the objectives of ensuring that environmental, social and economic sustainability are promoted throughout organisations’ activities and supply chains, and encouraging diversity through procurement activities.
Theme 3: Working together with Londoners
Actions under this theme should amplify the voices of residents and Londoners, especially those that are under-represented or face significant housing-related inequalities. Actions should form a legacy of early, pro-active and routine engagement with Londoners and for this to result in homes that are designed to meet the diverse needs of London’s diverse communities.
Partners are expected to develop actions and initiatives under this theme that will address barriers to inclusion. Engagement needs to be appropriately resourced, included from the earliest stages of the development process and ongoing. It is important to consider how to reach people across communities of geography and identity. This includes being pro-active about the methods and approaches used to reach the people they need to, and not relying on easier-to-reach groups as being sufficient.
This is also an opportunity to consider how partners engage with communities to develop their action plan.
Requirement guidance
The requirements must be met within 12 months after the allocation is confirmed (via OPS).
Where bids to the programme are received from consortia (that is, two or more individual organisations collaborating for the purposes of housing delivery), the requirements will apply to every member of the consortium.
* Reminder that conditions are met by the organisation (and not on a scheme by scheme basis)
Partners will be required to produce evidence of having met the requirements and share this with their appointed GLA Area Manager within five business days following the date 12 months after the allocations were confirmed.
This evidence is required per partner, for the first AHP 2021-26 allocation that is awarded. Such evidence must be satisfactory to the GLA, acting reasonably.
*Where organisations are not London based, partners may choose to benchmark against local workforce data.
Smaller organisations with fewer than 250 employees are exempt from four and five if these would risk breaching the privacy of individual employees. However, all organisations are encouraged to meet the requirements wherever possible.
The GLA’s Workforce Equality Data Guide includes guidance for SME.
Partners are required to have developed, published and begun to implement their EDI Actions Plans within 12 months of their funding allocation being confirmed.
Partners should provide a link to their published Action Plan and be able to describe how they have begun to implement it.
Partners will need to provide a progress update on their Action Plans annually following this – the progress updates will need to be published and are for GLA internal scrutiny.
The Action Plans must set out the actions Partners are taking to meet their objectives.
Area Managers, who manage relationships with the Mayor’s housing delivery partners, will review the published Action Plans to ensure they provide detail on the objectives, current baseline positions, the actions and tasks required to meet those objectives and target dates for when they will be met, and measures of success. These are set out in a template that Area Managers will work with to determine whether Action Plans meet the funding conditions.
Partners are welcome to complete this with the relevant information and submit to the GLA if they wish.
The requirement to satisfactorily evidence compliance with the five minimum standards and to develop, publish and begin to implement an EDI Action Plan within 12 months of a funding contract being entered into is a contractual obligation.
It is also a contractual obligation to evidence that the five minimum standards are met annually following this (including updating data) and that partners provide a progress update on Action Plans.
If Partners have not provided satisfactory evidence within 5 business days following the deadline (being the date 12 months after contracts have been entered into) that the requirements have been met by the deadline, this will trigger a 3-month remediation period.
The GLA will notify Partners within 10 business days following the deadline if either no evidence has been provided or the evidence is unsatisfactory, requiring a Remediation Plan.
Partners must submit a detailed Remediation Plan within 15 business days of the deadline (unless the GLA agrees an extension of time) setting out the partner’s proposals for how they plan to meet the requirements within three months from the deadline.
Following approval of the Remediation Plan by the GLA Partners must subsequently provide evidence within [5] business days of the expiry of the 3-month period, satisfactory to the GLA, that the requirements have been met in the remediation timeframe.
Should a Remediation Plan not be submitted within the required timeframe or the requirements still not have been met within the 3-month remediation period, the GLA may withhold both drawdown of existing funding allocations, and any future allocations of funding.
Useful resources
These can support partners to deliver on the EDI requirements in the AHP.
It is not an exhaustive list and includes a combination of GLA resources, as well as links to external tools and organisations.
- The Mayor’s Good Work Standard brings together employment best practice. To meet the standard, large organisations must meet 85 per cent of a list of requirements, within four ‘pillars’ (fair pay and conditions, workplace wellbeing, skills and progression and diversity and recruitment).
- The Mayor’s Supporting Diversity Handbook is a tool for advocacy, communication and action on the barriers to equality diversity and inclusion (EDI). It brings together research, examples of leadership and recommendations that can be applied at all career stages.
- The GLA Workforce Integration Network’s Inclusive Employers Toolkit is a step-by-step guide supporting employers to take action on representation and the inclusion of young black men. The Workforce Integration Network (WIN) is working to improve pathways for underrepresented groups in the workplace. The WIN programme will begin with supporting young black men aged 16 to 24 years into living wage employment in London. It will focus initially on the construction and digital sectors and will engage other sectors and groups over time.
- Workforce Equality Data Guide - provides practical, step-by-step guidance on how to collect, analyse and act on equalities data in your organisation. There is additional guidance specifically for SMEs as well as London Benchmarking Tool.
- The Social Value Portal – a tool and database for measuring, managing and reporting on the Social Value impact of a scheme or organisation.
- Equality, Diversity and Inclusion Evidence Base for London
- Inclusive London, the Mayor’s strategy for equality, diversity and inclusion
- The Mayor’s Construction Academy - To make sure Londoners benefit from the wide range of opportunities available in the sector, the Mayor set up his Mayor's Construction Academy (MCA), connecting Londoners to training in the skills they need to access vacancies in the capital’s developments, in trades, professions and management.
- Good Growth by Design – Good Growth by Design sets out a united programme of work to enhance the design of buildings and neighbourhoods for all Londoners. It is the Mayor’s plan to create a city that works for all Londoners.
- The Housing Diversity Network is a social enterprise that aims to inspire and empower people, promoting equality, diversity and opportunity for all. They work collaboratively to support organisations to improve how they address inequality, get the most from their staff and meet the needs of the communities they work with.
- Leadership 2025 is a charity working across the sector, together with our key stakeholders, to make the housing sector leadership more diverse.
- National Housing Federation Review looking at state of play in the housing association sector and outlining the actions that need to be taken to advance EDI.
- National Housing Federation case studies of best practice and blogs on EDI in the housing association sector.
- Unify BAME network for BAME housing association sector staff
- Wish GB network for women in social housing.
- BME landlords network of BME housing associations.
- The Architecture, Design and Urbanism Panel (ADUP) framework – a framework of consultants who can be appointed to provide design services related to architecture, urban design, place strategy, transport design, design advice relating to heritage, community engagement, environmental issues, smart cities and graphic design. In line with the Mayor’s priorities for Good Growth and social inclusion and diversity, the recommended ADUP assessment criteria is 70% for quality including social value, 25% for value for money and a further 5% awarded for the quality and project specific nature of bidders’ equality, diversity and social inclusion plans.
- HouseProud LGBT+ pledge card – aims to improve services and outcomes for LGBT+ residents. Requirement for partners to meet Pledge Pioneer status focused on improving LGBT+ resident input at executive level, increasing LGBT+ visibility and improving staff training and awareness of LGBT+ issues.
- Building People aggregates information, resources, activities and vacancies across the built environment, connecting diverse individuals to opportunities and enabling employers to easily widen their talent pools.
- Building Procurement is a procurement portal with a focus on social value, where procurers can search for diverse and local suppliers.
Need a document on this page in an accessible format?
If you use assistive technology (such as a screen reader) and need a version of a PDF or other document on this page in a more accessible format, please get in touch via our online form and tell us which format you need.
It will also help us if you tell us which assistive technology you use. We’ll consider your request and get back to you in 5 working days.