Policy paper

Diversity and inclusion strategy 2019 to 2023

Published 1 April 2019

Introduction from Michelle Russell (Chair of the Diversity and Inclusion Forum)

I am delighted to introduce the Charity Commission’s Diversity and Inclusion Strategy for 2019 to 2023.

I am passionate about promoting diversity and inclusion in all its forms, its importance and benefits and doing so beyond the legal minimum; the core basics of fairness and respect for difference, equality of opportunity and treatment across gender, disability mental and physical and different abilities, BAME and LGBT+ rights, championing those with caring responsibilities, including dementia care, part time workers and more.

We want to role model an inclusive environment, where every employee feels able to bring their whole self to work and feels comfortable sharing information about who they are (if they want to).

I am very proud of the impact of the work that has already been done in the Commission and the visible and lasting change that has been achieved; particularly the work on promoting good mental health, which has not only been fantastic in itself creating a safe space to talk about mental health issues and support colleagues but it has inspired engagement and the desire for change in other areas.

We are keen to replicate that success, respect and impact, in line with the aims of this strategy and implementation plan.

We know we have more to do on our own diversity. We recognise that our credibility and impact as a regulator is only strong, if we reflect and respect the hugely diverse nature of those in the charity sector and the public we serve. We want to improve our diversity in the areas we are not as representative as we should be and need to be.

We have set ourselves an ambitious goal - by 2023, we want an expected and natural consideration of diversity and inclusion in everything we do at all levels of the business. We need individually and as an organisation to lead by example. For this, we need a collective commitment to embrace and own not only the aims of this strategy but to make it happen.

We will hold ourselves to account for achieving this. For my part I promise to continue leading from the front on this agenda as Director champion and Chair of the Diversity and Inclusion Forum to promote, inspire, empower, support and challenge.

But it is together that we will make this reality, are greater in our impact and able to make positive and lasting change for the better.

I encourage everyone in the Commission to own this strategy and take an active role in making it happen.


The Charity Commission’s purpose is to ensure charity can thrive and inspire trust, so that people can improve lives and strengthen society.

To do this effectively we need to ensure we are outward looking and understand and appreciate the diversity of the sector we regulate and internally we have a workforce which is inclusive and diverse, and where employees fully represent and understand the public that we serve.

A diverse workforce brings a range of experiences and perspectives, which strengthen our performance and impact as regulator of a very diverse charity sector. This diversity and inclusion strategy seeks to add value to the Charity Commission, contributing to its effectiveness as a regulator and to its employee well-being and engagement.

We are committed to building an inclusive culture that is intolerant of discrimination, bullying and harassment. We get the best out of and support our employees where they feel included, supported and treated fairly. We do not tolerate bullying, harassment, discrimination or other negative behaviours.

We welcome respectful, constructive and professional challenge at all levels, without boundaries across roles and pay grades.

The government’s diversity and inclusion strategy focuses on equal treatment and equal opportunity. It states that ‘It is not right or fair that people are discriminated against because of who they are or what they believe. So we need to stop that discrimination and change behaviour. And it is not right or fair that the opportunities open to people are not based on their ambition, ability or hard work, but on who their parents are or where they live. So we need to break down the barriers that hold people back and give them the opportunities to succeed’.

The Charity Commission identifies with, and is aligned to, this definition of what is meant by equality; we will deliver this by focussing on diversity and inclusion.

The Charity Commission is committed to being a diverse and inclusive employer and regulator, supporting the Civil Service vision of becoming the UK’s most diverse employer.

The Civil Service diversity and inclusion plan focuses on 2 key aims to:

  1. Continue to increase the representation of currently under-represented groups at all levels across the Civil Service
  2. Focus on inclusion to build our culture and reputation as a place that attracts, develops, retains and fully engages all the diverse talent across our organisation

The Charity Commission is starting from a promising position, with higher representation from women than the Civil Service average. Half of our senior management roles are held by women. Our disclosure rate from employees with a disability is also higher than the Civil Service average, as is our representation in senior roles. However, there is more work to be done.

We must not rest on our laurels; we want to improve our reporting data and improve our representation in other areas, particularly BAME, whilst ensuring we continue to maintain strong foundations in terms of female and disabled representation. Our Black, Asian and Minority Ethnic (BAME) representation is below the Civil Service average and none of our senior leaders in 2017/18 declared themselves as BAME.

Our diversity data reporting needs to improve, for example, we will aim to increase our diversity data recording for sexual orientation to at least 70%.

Research shows that diverse teams are higher performing, more engaged and more innovative.

There are many studies with outcomes that support this, you can explore these in more detail.

Why diversity matters – McKinsey

Why diverse terms are smarter – Harvard Business Review

Gender Diversity and Corporate Performance - Credit Suisse

Breaking bias – NeuroLeadership Institute

This plan sets out our strategy for maintaining current areas of success and addressing areas for improvement.

Being a diverse and inclusive employer will not only support the Commission to develop a positive working environment that recognises and values difference. It will support us in effectively regulating the charity sector, with a better understanding of what they do and who they in turn support, the public and in speaking with a credible voice to encourage improved diversity and inclusion within charities.

It will also firmly embed diversity and inclusion in our regulatory outcomes.

Our Diversity and Inclusion Strategy

We recognise that to realise the benefits of diversity and inclusion, we will need to focus on 4 key objectives:

  1. Meeting our statutory requirements and going beyond this by taking positive action and building a culture that champions diversity and inclusion

  2. Maintaining our representation where we are doing well and improving our representation in areas where we could improve

  3. Creating an inclusive culture, that values diversity, in how we treat each other and interact with those that we regulate and come into contact with

  4. We want Diversity and Inclusion to be a natural part of what we do – firmly embedded in our culture

Meeting our statutory requirements

The Commission will continue to meet its core statutory responsibilities by ensuring that we are compliant with the Equality Act.

The Equality Act legally protects people from discrimination in the workplace and in wider society. The Commission does not tolerate direct or indirect discrimination, victimisation or harassment full stop, in relation to the below protected characteristics:

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

We will ensure:

  • our internal policies and procedures remain up to date, are compliant with the law and reflective of best practice, where achievable
  • there are clear, well communicated procedures in place explaining how to raise concerns or complaints. All issues will be taken seriously, no matter who they are from or who they are involve. They will be considered and acted upon with a focus on independence, timeliness and impartiality. We will ensure that appropriate support is in place for those who raise complaints. As an organisation, we will learn lessons from complaints and encourage the individuals involved, to do so too
  • we raise awareness of our equality duties specifically around protected characteristics and our wider commitment to equality and inclusion;, ensuring that all employees are aware of their responsibilities and the behaviours we expect through use of training and consistent messaging and role modelling from Directors and the Board.

We will report our gender pay gap on an annual basis and will take action to address disparities.

We will comply with the public sector equality duty which requires public authorities, in carrying out their functions, to have due regard to the need to achieve the objectives set out in the Equality Act to:

  • eliminate discrimination
  • advance equality of opportunity
  • foster good relations between different people when carrying out their activities

To ensure transparency, and to assist in the performance of this duty, the Equality Act requires public authorities to publish:

  • equality objectives, at least every 4 years
  • information to demonstrate their compliance with the public sector equality duty

Maintaining our representation where we are doing well, and improving our representation in areas where we could improve

Increasing representation is one indicator of how successfully we are creating an inclusive workplace and building strong diverse teams. Diversity at all levels within the Commission will improve our effectiveness and productivity.

Ethnically diverse companies are 35% more likely to be in the top-performing quartile (McKinsey, 2015, ‘Diversity Matters’). Plus, it’s the right thing to do - the chances provided to people shouldn’t be linked to skin colour, age, religion, sexuality, gender or disability; just as they shouldn’t be linked to where they grew up or went to school.

Our key aims are:

to be open and transparent about our representation

We will be open and transparent on both areas we do well in and where we want to improve. We will ensure the results are discussed at Board, Director and senior management levels, as well as with our employees, including through our Diversity and Inclusion Forum.

We will report our progress publicly on an annual basis. We will take action to address any areas for improvement.

to take action to improve under representation for those groups at all levels

We will ensure we recruit and promote talent from and opportunities to all sections of society to ensure the Charity Commission is open to all.

We are committed to going beyond our statutory requirements; our focus on diversity and inclusion will not be limited to protected characteristics. For example, we want to be mindful of social inclusion issues.

We will start capturing the socio-economic background of our employees so that we can take steps to ensure it is representative of the diverse sector.

We will ensure that our recruitment is fair, open and inclusive. We have already taken steps to ensure candidates are not identifiable in the sifting stages. We will incorporate strength based assessments in to our processes, to ensure a more open, inclusive approach to assessing candidates.

We will ensure our internal processes and procedures have inclusion at their heart so that we can retain diverse talent.

We will increase representation at senior levels by participating in Civil Service positive action initiatives such as the Minority Ethnic Talent Association (META), Levelling the Playing Field and the Summer Diversity Internship Programme (SDIP) to support equality of opportunity.

Our managers are required to hold regular development and career conversations with staff, to help ensure all staff have equal opportunities for learning, training and professional development. The learning and development team will also analyse and report on the requests that they receive.

Creating an inclusive culture, that values diversity, in how we treat our employees and interact with those that we regulate

Fostering a culture of inclusion will enhance our employer brand, attractiveness and improve our regulatory outcomes.

Creating a culture of inclusion will also be critical to improving and maintaining representation. We will develop greater inclusivity in our culture by:

  • ensuring that diversity and inclusion is a key objective in our Corporate and Directorate business plans and Commission people strategy, holding the Directors Group and senior leaders to account for delivery of these objectives. We recognise that a change in culture needs to be role modelled from the top

  • raising awareness of protected characteristics, our responsibilities and the benefits of diverse and inclusive teams. Educating our workforce to improve understanding of barriers faced by particular groups so that all employees can help to remove these barriers, for example, improving the accessibility of documents

  • creating an environment that promotes disclosure of diversity characteristics and understanding of why that is important

  • increasing the visibility and effectiveness of champions and staff networks

  • consistently demonstrating inclusive, nurturing leadership at all levels – learning and development activity will support this

  • taking seriously and acting upon allegations of inappropriate language, situations or practices and have the skills to mediate and investigate issues as soon as they arise, promptly at the root cause

  • committing to getting the basics right – appropriate reasonable adjustments being consistently put in place for colleagues in a timely manner, with sufficient budget set aside to do so

  • actively focussing on Civil Service inclusion measures

  • continuing promotion of mental health action so it is prioritised equally with physical health

  • promoting flexible working and job share at the Charity Commission to deliver excellent working arrangements which meet business needs, whilst providing innovative and flexible solutions tailored to and supportive of individual needs and differences

  • promoting our commitment to Diversity and Inclusion throughout the procurement process and in relationships with suppliers


Diversity and Inclusion is the responsibility of all staff to contribute to creating an inclusive culture and environment.

The Directors Group will both be ultimately accountable for, and hold other staff to account for, the delivery of the 4 aims that are outlined within this Diversity and Inclusion Strategy.

Implementation Plan

Some of what we need to do to achieve our aims is embedded as business as usual. However, we will also take some specific actions to complement business as usual and achieve further changes.

They will be recorded on an implementation action plan that will be continually updated and progress will be assessed by the Diversity and Inclusion Forum, and progress reported on to the Directors Group at least once a year.

Measuring progress

The implementation plan will include measurement against the following below criteria:

  • a suite of diversity statistics to be produced and analysed by HR quarterly
  • public sector equality duty – reported upon and analysed annually
  • gender pay gap data
  • learning and development data
  • annual people survey – bullying, harassment and discrimination scores
  • benchmarking against the broader Civil Service
  • benchmarking against the geographical local population for each office
  • this strategy is to be reviewed in 2023