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energywatch

Race Equality Scheme2004 – 2007

July 2004

energywatch Race Equality Scheme

Gas and Electricity Consumer Council (energywatch)

CONTENTS

Foreword by Allan Asher, Chief Executive Page 1

Section 1 Introduction

Section 2 energywatch – who we are Page 3

Section 3 Meeting the General Duty Page 6

Section 4 Assessing our Functions Page 9

Section 5 Monitoring Employment Page 15

Section 6 Complaints About Failure to Comply

With the Specific Duties Page 18

Annex A Year 1 Action Plan Page 19

Annex B Action Plan Timetable for 2004/2007 Page 20

Annex C Classification of Operational Functions by

Relevance to the General Duty Page 21

Annex D Classification of Support Functions by

Relevance to the General Duty Page 22

Foreword from Allan Asher, ChiefExecutive,energywatch

energywatch, as a grant-aided publicbody, is committed to race equalityand diversity. We regard unfairtreatment and any form ofdiscrimination as unacceptable, andwe believe that it is in our bestinterest, that is, of our staff and thecommunities we serve, for diversityto be valued and celebrated. Weemploy staff from the wide racial mixof the UK multi-cultural society andwe believe that the positive benefitsthat accrue from this are a workingenvironment that is free from racialdiscrimination or harassment.

Our mission is to champion theinterests of all consumers whichmeans taking positive steps to meetthe needs of all the communities. Wehave recently been focusing on theneeds of vulnerable consumers, andthe action plan established in ourRace Equality Scheme gives us theopportunity to better provide for theneeds of the Ethnic Minorities.

In preparing its Race Equality Scheme,energywatch is building on its existingvalues of equality of opportunity foreveryone. We value everyone’scontributions and we respect andtreat everyone fairly.We believe thatthis creates an inclusive culture withinthe organisation where issues relatingto racism, stereotyping anddiscrimination can be openlydiscussed and challenged.

Following a public consultation on thedraft Race Equality Scheme, whencomments were received from boththe public and the staff, I am delightedto introduce energywatch scheme forthe period 2004/2007. In thisdocument, which has been approvedby the energywatch Council andwhich has the full support of mysenior colleagues, we have set outhow we will carry out our statutoryresponsibilities over the life span ofthis scheme. During the course ofthe scheme we will train our staff ontheir obligations under the Act, andcarry out the necessary changes thatare required to ensure that ourpolicies and functions reflect thegovernment’s aims to modernisepublic services, and promote raceequality. Central to this will be theexamination of our existing andfuture functions and policies on aregular basis. Additionally, we will putin place a system of monitoring andscreening the work we do.

This is challenging work. But I amdetermined, and with the support ofenergywatch staff, we will achieve thegoals we have set for energywatch inthis Race Equality Scheme.

Allan Asher

Chief Executive

July 2004


1Gas and Electricity Consumer Council (energywatch)

energywatch RaceEquality Scheme

Section 1

1 Introduction

1.1 The Race Relations (Amendment) Act2000 places a General Duty on somepublic bodies - including energywatch– to promote Race Equality.energywatch consider that the bestway of meeting the General Duty isthrough the preparation andpublication of a Race Equality Scheme(RES). The aim of the RES is to setout what steps energywatch will taketo make sure its policies, servicedelivery and employment systemshave ‘due regard’ to the need totackle institutional racism byeliminating unlawful racialdiscrimination, promoting equality ofopportunity, and promoting good racerelations between people of differentracial groups.

1.2 The General Duty is supported byspecific duties. Specific duties providethe steps, methods and arrangementspublic bodies should follow to helpthem meet the requirements underthe General Duty.

1.3 The energywatch RES summarises itsapproach to race equality and itscorporate aims. It also sets out howenergywatch plans to carry out eachpart of the specific duty – in otherwords – its arrangements for:

Identifying the functions andpolicies which may affect peopledifferently ( the relevant functions);

Assessing and consulting on thelikely impact of its functions andpolicies on the promotion of raceequality;

Consulting people, including staff,to ensure that people from someethnic groups are not put at adisadvantage;

Monitoring energywatch functionsand policies for adverse impact onthe promotion of race equality;

Ensuring that mechanisms are inplace so that people can access theinformation that energywatchprovides;

Setting out how the results ofassessments, consultations andmonitoring will be published;

Ensuring energywatch employmentmonitoring and the publication ofthe results of the monitoringmatches the requirements set outin the Act;

Ensuring that staff are properlytrained in their responsibilitiesunder the Act.

1.4 Enquiries, comments and complaintsabout the scheme should beaddressed to:

Equalities Officerenergywatch 4th Floor, Artillery House, Artillery RowLondon, SW1P 1RTe-mail: [email protected]



Section 2

energywatch – who weare and what we do

2.1 energywatch is the independent gasand electricity consumer watchdog,established by Parliament inNovember 2000. We provide free,impartial information and advice andtake up complaints on behalf ofconsumers who have been unable toresolve problems directly with theirenergy companies. However, mostconsumers prefer to deal with theirown problems rather than go throughour complaints handling process. Wewill, therefore, explore the potentialfor energywatch to act in a moresupportive and advisory way than bydirect intervention in disputes.Consumers need to be able to accessaccurate, impartial information andadvice to support them in theirdealings with gas and electricitycompanies. By providing consumerswith the information and tools theyneed, we can further concentrate ourefforts on those consumers who feelunable to help themselves. In this,one of energywatch key objectiveswill be to identify the ethnic minoritygroups and determine how best wecan serve their needs as consumers.

2.2 Under the Utilities Act 2000,energywatch has a statutory duty toprotect and promote the interests ofenergy consumers in England,Scotland and Wales. We also have aspecific duty to ‘have regard’ to theinterests of consumers who are ofpensionable age, living with disabilities,chronically sick, on low incomes, orresiding in rural areas. Not all people

within these groups are vulnerableand one of our aims over the periodwill be to improve our understandingof who needs more help and whatthat should be.

2.3 Our objectives are to ensure thatsuppliers deliver on their obligations;we are building productive and lastingrelationships with supply companiesto prevent debt, debt blocking andend disconnections for domestic (andvulnerable business) consumers. Weare working towards achieving anextension of the winter fuelallowance to people with severedisabilities. We will continue to be astrong advocate for consumers in thedebate and implementation ofsustainable energy policies.

2.4 energywatch has had a significantimpact with campaigns to improve theconsumer experience. These includeencouraging switching, making thecase for better standards of billingand greater protection for vulnerableconsumers. They will become anincreasingly significant part of ourfront-line approach to deliveringchange for consumers. We willcontinue to involve our partners andstakeholders in delivering thecampaigns. We will also continue toensure that all our campaigns aretargeted to reach ethnic minoritygroups.

2.5 We believe research is critical toplanning and successful delivery ofchange. We have put in place aframework of collecting informationand evidence from consumers,including the ethnic minority groups.This information will help inmainstream planning and the reviewprocedures and will be reflected in



our Corporate Plan and the ForwardWork Plan.

2.6 We carry out work from eight officeslocated in England, Scotland andWales. We employ some 300 staff ofwhom some 200 are ConsumerAdvisers providing a dedicatedinformation and advice service toconsumers and delivering ourprogramme of Reachout activity.

energywatch mission, keyaims and values

2.7 energywatch mission:

To be independent consumerchampion, dynamic in developingsafe, confident and assertiveconsumers and committed toimproving the services provided toall the gas and electricitycustomers.

2.8 energywatch Core Values are to:

Be close to and effectivelyrepresent, enable and empowerthe consumer to exercise choice inthe marketplace.

Value and invest in our staff so thatwe may deliver services to thehighest standards ofprofessionalism.

Be an effective and efficientorganisation, focused on resultsand measuring the contribution wemake.

Be open, honest and transparent inall our dealings.

Provide value for money in all wedo.

2.9 energywatch key aims for the nextfour years are to:

Deliver one stop service, providingadvocacy, dealing with complaintsas well as providing clear andaccessible information and advice.

Ensure that our knowledge ofconsumers and the energy marketenables us to provide informationat point of need.

Foster confident and assertiveconsumers who know their rightsand to help them put pressure oncompanies to get better deals andimproved service.

Champion the interests of allconsumers, particularly those whoare vulnerable, and drive theconsumer agenda throughcampaigns and working with allstakeholders to provide betterservices.

Work with companies to improvecompliance, raise standards, stopcomplaints arising and ensure agenuine effort is made to meettheir social obligations.

Work with the regulator andothers to ensure the structure ofthe market is competitive and thatdetriment is removed throughregulatory action and prosecutions.

Campaign for the eradication offuel poverty and the delivery ofreal benefits for low incomeconsumers.



2.10 In delivering our key aimsenergywatch will measure itseffectiveness by ensuring that ourevaluations of effectiveness in dealingwith consumer complaints include theimpact they may have on differentethnic or racial groups.

Our equality value

2.11 energywatch is committed to meetingits obligation under the General Dutyto eliminate racial discrimination andprovide equality of opportunity for all.We will achieve this by utilising theexisting structures, systems andprocedures and, where appropriate,put in place new ones. We will usethe specific duties to make raceequality an integral part in thedelivery of our policies and services,and in the way we manage anddevelop our staff. We will ensure thatenergywatch equality objectives andany targets are integrated into itsannual forward works programme,and its corporate strategy.

Diversity

2.12 energywatch is committed to theprinciples of equal opportunity for allits employees and opposes all formsof unlawful and unfair discrimination.energywatch values and respects thediversity of its staff, and respects thecontribution individuals make, andrecognises the benefits thatdifferences can bring to theorganisation.



Section 3

Meeting the GeneralDuty3.1 Although overall responsibility for the

energywatch RES rests with AllanAsher, the Chief Executive, apermanent working group has beenestablished which has theresponsibility of drawing up,implementing and monitoring thescheme and it will co-ordinate actionwithin the organisation to ensure thatenergywatch complies with itsobligations under the Race Relations(Amendment) Act.

3.2 The membership of the workinggroup has been drawn from differentracial groups from withinenergywatch, and includes a tradeunion representative. Co-ordinatingthe day- to- day running of thescheme rests with the EqualitiesOfficer. However, it will be theresponsibility of the working group toensure that the work identified in thefirst year’s action plan (Annex A) iscompleted on time.A summary of thethree year action plan timetable(Annex B) is attached.

3.3 The scheme will be reviewed annuallyby the working group, and at the endof the three year period, the workinggroup will review the RES 2004-2007,and introduce a revised new schemefor the following three years. TheRES will be publicly available on thewebsite as will the annual reviews ofthe scheme.

3.4 The success of the policy will dependon the effective leadership given byCouncil and the management, and by

staff at every level of the organisation.In order to achieve success, theworking group envisages the followingresponsibilities:

Council

3.5 Council members are responsible forensuring that:

The Chairman, through regularmeetings with the sponsoringdepartment, draws to theirattention that the membership ofthe Council reflects thecommunities they serve.

The membership of the LayCommittees reflects thecommunities that they serve,

energywatch Corporate Plan andthe Forward Work Programmeinclude a commitment to RaceEquality.

They are aware of theenergywatch statutoryresponsibilities in relation to racelegislation as an employer and as aservice provider.

They receive and respond to theracial group monitoringinformation in the annual Equalityand Diversity Report.

3.6 To achieve this, Council will:

Receive appropriate briefing ontheir obligations under the equalityduties.

Require all reports submitted forits consideration that set out howrequirements of the General Dutyand the specific duties are beingmet, and how race equality is beingpromoted.



Require the Chief Executive toestablish equality and diversityimpact measures including raceequality measures as an assessmenttool in quality assurance.

Receive an annual Equality andDiversity report.

Annually review its own, and thelay committees, ethnic profile andtake any necessary action.

In formulating the work plan, givedue regard to the demographicand socio-economic context of thecommunities serviced byenergywatch.

Chief Executive Officer(CEO) and TheManagement Board

3.7 The CEO and the Directors (GradeA) are responsible for giving leaddirection on race equality andensuring that policies and functionsfor which they are responsible reflectthe statutory requirements of theAct. They will ensure that they will:

Undertake appropriate training.

CEO to report progress toCouncil annually through theEquality and Diversity report.

Ensure their Directors, Heads ofService, and Staff DevelopmentManager undertake training.

Require that all monitoring,assessments and review reportsset out how the requirements ofthe General Duty are being metand how race equality is beingpromoted.

Keep the ethnic profile ofDirectors, Heads of Service andSenior Managers under review.

Include race equality indicators inthe management, and in theappraisal of their staff.

Ensure that the Corporate Planand the Forward Work Programmereflect the requirements of theGeneral and Specific duties.

Establish formal communicationwith staff and consumers toreinforce commitment to raceequality.

Promote energywatch as anequality and diversity leader.

Ensure that there are appropriateand realistic plans for achieving arepresentative workforce.

Directors and Heads ofService

3.8 Directors and Heads of Service areresponsible for ensuring that:

They are aware of energywatchstatutory duties in relation toracial equality issues.

Their staff set an example increating a positive and inclusiveethos in the workplace thatchallenges racist or inappropriatebehaviour on the part of managers,staff and consumers.

All aspects of energywatch policiesand functions reflect racial issues.

Ethnic monitoring is undertakenand information is collected andanalysed.



The procedures for recruitmentand promotion of staff reflect bestpractice in equality opportunities.

Analyse the recruitment andpromotion of staff based on ethnicmonitoring information, compare itwith the demographic and socio-economic make up of thecommunities serviced by its Hub,National and Regional offices andtake action to remedy anyimbalances.

energywatch publicity andinformation materials presentappropriate and positive messagesabout ethnic minorities.

Include race equality indicators inthe management and appraisal oftheir staff.

Ensure that staff understand theircommitment to racial equalitylegislation.

energywatch staff

3.9 energywatch staff are responsible forensuring that:

They are aware of energywatchstatutory duties under thelegislative framework.

They challenge inappropriatebehaviour by consumer,contractors or other members ofstaff.

They undertake training offered byenergywatch.

They include race equalityindicators in the management andappraisal of any staff they manage.

They ensure a secure and inclusiveworking environment for all staffwhich values diversity.



Section 4

Assessing ourfunctions and policies,or proposed policies,for relevance to thegeneral duty4.1 The General Duty applies only where

it is relevant. The Commission forRacial Equality’s (CRE) statutoryCode of Practice on the duty topromote race equality defines‘functions’, ‘policies’ and ‘relevant’ asfollows:

‘functions’ means the activitieswhich energywatch performsunder its duties and powerscontained in the Utilities Act 2000.It covers internal and externalfunctions including service delivery.

‘policies’ means the full range offormal and informal decisionsenergywatch makes in carrying outits functions and in all other waysit uses its powers. Any assessmentof a policy includes an examinationof longstanding ‘custom andpractice’ and managementdecisions, as well as any formalwritten policy.

‘relevant’ means ‘about the extentto which a function or policyaffects people, as members ofpublic and as employees of theauthority’.

4.2 The CRE’s code of practice statesthat ‘to decide whether a function orpolicy is relevant to the general dutyto promote race equality, publicauthorities should consider whether

the function or policy could affectdifferent racial groups in differentways or affect good race relations’.To identify which energywatchfunctions are relevant in relation tothe general duty, the working grouphas drawn up a comprehensive list ofits current policies, functions andactivities which are consistent with itsstatutory duties under the UtilitiesAct 2000. Having identified ourfunctions, the working groupconsidered the relevance of thefunctions and polices to the duty topromote racial equality.

4.3 Adopting a simple marking system forthe initial assessment, and using thesuggested ‘grid’ in CRE’s A Guide forPublic Bodies, the working groupclassified its functions and policies onthe basis of:

How much evidence do we havethat a function was affecting someracial groups differently – none, alittle, some or a lot (e.g. fromresearch, consultation, complaints,or ethnic monitoring)?

Are the public (especially ethnicminority communities) orstakeholders concerned thatcertain functions or policies arediscriminatory?

4.4 In considering what priority to give toeach function the working group wasaware that in significant number ofcase, no hard statistical informationwas available, and our assessment onpriority was given on the basis ofanecdotal evidence. For the future,we will review the relevance of thefunctions over the life of this schemeas data and information becomeavailable as part of the monitoringprocess.



4.5 The working group carried out aninitial screening process and classifiedits activities into three broad prioritycategories: High, Medium and Low/Nil.In categorising the functions, theworking group was mindful to ensurethat energywatch has ‘due regard’ tothe general duty. The CRE Code ofPractice states that, ‘due regard‘means that the weight given to raceequality should be proportionate toits relevance to a particular function.In practice this kind of proportionateapproach may mean giving greaterconsideration and resources to thosefunctions that have most effect on thepublic. The results of the classificationare shown at Annex C and D.

4.6 Although we have no evidence thatour functions or policies have had anyadverse impact on race equality, wehave decided to carry out full impactassessment on the four functionslisted below, which in our view, have ahigh relevance to the general duty.The carrying out of full impactassessment will give the workinggroup and the relevant Directoratesan opportunity to review ourpractices in these particular policyareas.

Dealing with Business consumers.

Preparation and publication ofCorporate strategy

Printing and publishing informationleaflets.

Training and Development.

4.7 The working group will meet theindividual directors where functionsand policies have been classified as‘High’ impact and assist them inscreening process for relevance andidentify their training needs. At the

same time the working group willagree arrangements for monitoring;for the publication of assessment,consultation and monitoring reports;ensuring public access to informationand services, and staff training.

Assessing, and consultingon, the likely impact ofproposed new schemes

Assessing

4.8 Apart from employment, we currentlydo not have the necessary ethnic datato properly assess our policies andfunctions for impact. Howeverthrough the proposed trainingprogramme, energywatch will ensurethat policy makers establish anappropriate procedure to properlyassess the likely impact their policymight have on some racial groups andwhether it will contribute to goodrace relations.This will ensure thatwe mainstream equality and diversityin the development of our proposedpolicies and service delivery.

4.9 Like most public authorities,energywatch will not have to assessevery policy for impact. This isbecause energywatch will apply thetest of relevancy and proportionalitybefore it proceeds to the next stage.The initial assessment will be madeon the basis of information available.If the initial screening shows thatracial groups will not be affecteddifferently by the policy, or that theproposed policy has a low relevanceto race equality, then energywatchwill not move to the next level ofassessment. However, once the policyhas been established, it will continue



to be monitored periodically andchanges made to it if new evidencecomes to light.

4.10 If full impact assessment is required,we will:

Set clear policy aims andobjectives;

Collect existing ethnic data andcommission research if necessary;

Use the data to decide whetherthe policy is likely to affectdifferent racial groups, directly orindirectly, in different ways;

Consider changes to the policy toprevent any adverse impact orunlawful discrimination, while stilldelivering the aims of the policy;

Consult interested parties;

Take account of all assessmentsand consultations before making afinal decision on the policy;

Monitor and review the policy andits impact; and

Publish the results of the impactassessment, consultation, andmonitoring.

4.11 Where we identify a potential oractual adverse impact on a particularethnic group or groups, we willreview the policy and if necessary:

Take any steps necessary to lessenany such adverse impact;

Consider special monitoring andanalysis to confirm the extent ofthe adverse impact;

Take into account any informationcollected through the additionalmonitoring in future reviews of thepolicy.

Consulting

4.12 At present energywatch consults keystakeholders, including staff, onpolicies as they are developed, and onoccasions when changes of asignificant nature are contemplated.Methods used have been seminars,conferences, draft consultationdocuments, satisfaction surveys, openmeetings etc. We will continue toconsult people, including staff, aboutfuture energywatch policies andfunctions and extend the consultationprocess to all groups which have alegitimate interest in our work. Wewill continuously review the groupswe consult to ensure that they arerepresentative of the bodies that weneed to consult, and if appropriateand if there is a clear demand for it,we will make documents available inlanguages other than English.

Arrangements formonitoring policies foradverse impact

4.13 Without the availability of dataconcerning minority communities,there is no reliable way of knowingthat energywatch is meeting therequirements of the general duty.Therefore, depending on the natureof the policy and its possible effectson different people, energywatch willput specific arrangements in place andit will:

Set up monitoring for all relevantfunctions and policies;

Analyse data from monitoring;

Decide what action is needed todeal with issues identified bymonitoring data;



Change functions or policies asappropriate;

Publish the results of monitoring.

4.14 energywatch will consider the bestmethod for monitoring each functionor policy depending on thecircumstance in each case. Methodsavailable will include:

Statistical analysis of ethnicmonitoring data;

Satisfaction surveys - analysed bythe racial groups to which thepeople surveyed belonged;

Random or targeted surveys;meetings, focus groups, or citizensgroups.

Our monitoring activity should producethe following outcomes:

No significant difference in serviceoutcomes between differentgroups.

No significant difference in levelsof satisfaction between groups ofconsumers (by ethnic background).

Increased representation by ethnicminorities on Council, Scottish andWelsh Lay Committees.

We will link the specific outcomes to KeyPerformance Indicators (KPI’s). These willbe:

Race Equality issues to have beenincorporated in all energywatchcampaigns.

No significant differences inconsumer satisfaction withcomplaint handling.

No significant differences inconsumer awareness ofenergywatch.

Satisfaction rates in relation to‘Reachout’ reflect therepresentation of ethnic minorityconsumers.

Ensuring that people canaccess our informationand services

4.15 energywatch is committed toensuring that everyone, whatevertheir racial group, is able to getinformation about its functions andpolicies. However, it also recognisesthat in practice certain sections of thecommunity will not be able to accessthe information for a number ofreasons. We will, therefore, need tofocus on people who do not knowabout our services, or those who facedifficulties in accessing theinformation because of languagebarriers. In making accessibility toinformation and services a priority,energywatch will consider:

the requirements of the DisabilityDiscrimination Act 1995;

its duties under the freedom ofInformation Act 2000;

what information needs to becommunicated to which groupsand how best to achieve this;

what information energywatchcurrently provides and how it isprovided;

the likely demand for informationin alternative formats; and

resource implications forenergywatch.

energywatch CommunicationsDirectorate has the responsibility forensuring that information about theorganisation and the services it



provides is available to peoplethrough its website, or ordering it inpaper format.

energywatch will consider the bestways of communicating with staff,customers, and the public includingthe ethnic minority customers.

Publishing the results ofassessment, consultation,and monitoring

4.16 energywatch currently publishes awide range of information, whichincludes leaflets, annual report, annualforward work programme, corporatestrategy,e-bulletin, job vacancies andother material on its website. Mostof the material is published topublicise energywatch work and it isdistributed to stakeholders. We willuse the website and the Equality andDiversity report to publish results ofconsultations, assessments andmonitoring. The information will beavailable in the most appropriateformat and it will be free of charge.However in keeping with therequirements of the Data ProtectionAct 1998, some information may notbe published.

Arrangements formanagement and stafftraining and development

4.17 In order to meet the requirements ofthe General Duty, i.e., that the aims ofrace equality and diversity areembedded in energywatch policiesand functions, energywatch willensure that Council receiveappropriate briefing, and that

management and staff receiveappropriate training and development.Therefore, energywatch will review itsexisting equal opportunities anddiversity training programmes, anddevelop and deliver a trainingprogramme for all staff which willinclude training on the general andspecific duties in the following way:

general training for all staff tomake sure that they are aware ofthe general and specific duties, andhow these affect them and theirwork. This will be undertakenthrough the induction programmefor new staff. For existing staff wewill run seminars to ensure thatthey are familiar with the dutiesand how these affect their work;

we will develop a specific skills-based training for those staffinvolved in the development ofpolicy and service delivery. Thiswill include: how to carry outimpact assessments, consultation,and monitoring; and how toproduce and publish reports onassessments, consultations andmonitoring, and publicise themwidely.

Procurement

4.18 A number of energywatch functionsare contracted out to organisations inthe public and private sectors, orcarried out in partnership withprivate companies and voluntaryorganisations. Where procurementfunctions are relevant to the generalduty, energywatch will ensure that itmeets its obligation when dischargingits functions with or through otherbodies.



energywatch will, therefore:

Review its procurement process toensure that race equality and equalopportunities elements areincorporated into specificationsand associated supplierrequirements.

Require confirmation fromsuppliers and contractors that theyhave effective race equality policiesin place.



SECTION 5

MonitoringEmployment5.1 energywatch is bound by the specific

duty to monitor employment. Theduty requires us to monitor ouremployment processes by racialgroups and publish the results eachyear.

Monitoring will involve collecting,analysing and evaluating information,to measure performance, progressand change against key performanceindicators. Monitoring by racial groupwill give energywatch the informationit needs to understand how itspolicies, practices and proceduresaffect staff from differentbackgrounds. energywatch will usethis knowledge to highlight possibleinequalities, investigate theirunderlying causes, and remove anyunfairness and disadvantage in allaspects of employment and training.

The monitoring will capture the followinginformation:

staff in post

applicants for employment, training,and promotion.

staff receiving training.

staff who benefit or suffer fromperformance appraisals.

staff involved in grievance anddisciplinary action.

staff who end their service with us.

Ethnic categories and the2001 census

5.2 The ethnic classification system usedby energywatch in monitoringemployment is in accordance with2001 census categories.

Data protection Act 1998

5.3 In collecting, storing, analysing andpublishing ethnicity data, energywatchwill take full account of the DataProtection Act 1998.We will explainto staff that the information wegather will be confidential and it willbe used only to produce statisticalinformation.

Staff in post

5.4 energywatch already monitors itsentire workforce by reference to theracial groups identified in the 2001census categories, and additionally,captures information on disability,gender and by grade. energywatchlast ran a survey in February 2003 ofall its staff to update its records; theresponses were voluntary and by selfnomination. energywatch iscontinuing to make a determinedeffort to improve the data it holds onits staff by undertaking regularsurveys.

The profile of the staff in post revealsthat a majority of the minority ethnicstaff are at Consumer Advisor level.The profile has also revealed thatsome of the regional/national officeshave no ethnic minority staff. This isof some concern to energywatch anda number of measures are beingconsidered to address this problem.



Staff in post figures are made availableto the Trade Union side and will bepublished in the energywatch AnnualReport, and the Equality and Diversityreport annually.

Recruitment

5.5 All external recruitment exercisesrequire applicants to provideinformation on their ethnic origins.However, to present a clearer pictureof what is happening during therecruitment cycle, energywatch willmonitor information at each stage ofthe recruitment process by ethnicorigin ( i.e. applications received,invitations to interview, offers ofemployment, take up of employment). The results will be published in theenergywatch Equality and Diversityreport.

5.6 It is not our intention to set rigidtargets but energywatch, bymonitoring the emerging information,will examine the reasons for the lackof applications and success rates andtake necessary steps to correct anyunder representation of ethnicminorities.

Promotion

5.7 energywatch will monitor its internalpromotion processes by analysing theapplicants, short listed staff, andnumbers of staff promoted by ethnicorigin and publish the results in itsEquality and Diversity report.Similarly, energywatch will examinethe reasons and take correctiveaction if applications and successrates indicate that there is under-represenation.

Performance Appraisal

5.8 energywatch has recently introduced anew annual appraisal procedure whichalso involves consistency panels. Therole of these panels is to ensure thatappraisals are consistent and that allstaff are treated fairly.

energywatch has not, in the past,analysed its performance appraisalsystem by ethnic origin but theinformation has been available on itsdatabase. For 2004/2005,energywatch will analyse thisinformation and publish it in theEquality and Diversity report.

Grievance/Discipline

5.9 The number of cases dealt with eachyear is so small that energywatch hasnot published the information byethnic origin for fear of misleadinginference being drawn from the smallsample, and the identity of the staffconcerned becoming known.energywatch will consider verycarefully, taking into account thenumbers affected, whether thisinformation should be published.

Reasons for leaving

5.10 energywatch collects but does notpublish the information by ethnicorigins. However, in order to ensurethat there is a consistency ofinformation, energywatch will producea questionnaire which will enableleavers to record their reasons forleaving. This information will allow usto carry out an analysis of leavers byethnicity. We will publish thisinformation in a statistical format inthe Equality and Diversity report.



Access to training

5.11 The central tenet in the provision oftraining is that it should underpin theaims and objectives of energywatch indischarging its duties and meeting itskey business objectives. Trainingneeds are assessed and developedthrough a consultation process withthe directors and senior managersand included in the corporate plan.Procurement and delivery of thistraining is normally managed from theHub. Where an essential individualtraining need is identified and which islinked to energywatch business needs,funding is made available for thecourse to be undertaken.

5.12 Additionally, directors produce localtraining plans aimed at filling specific‘knowledge’ gaps; this training isdelivered by local senior staff or byexternal sources e.g.Transco, on gasrelated issues.

5.13 Since there is limited centralrecording and monitoring of theinformation on training, energywatchhas decided to develop a systemwhich will provide a morecomprehensive picture of trainingundertaken by staff, both centrally andlocally, and which will then be linkedto their ethnic origins. Thisinformation will be collected andpublished in the Equality and Diversityreport and on the website.



Section 6

Complaints aboutfailure to comply withthe specific duties6.1 Under the Race Relations

(Amendment) Act, the Commissionfor Racial Equality (CRE) has thepower to enforce the specific dutieson the listed public bodies, includingenergywatch. Individuals do not havethe right to take legal action againstenergywatch if it has not fulfilled itsspecific duties. However, it is open toindividuals, staff, communityorganisations, trade unions,stakeholders and others to notify theCRE if they are concerned thatenergywatch has failed to complywith the specific duties.

6.2 If people and staff have any concernsor complaints about our RES, wewould encourage them to raise thesewith energywatch in the first place.These should be sent to the EqualitiesOfficer (details are at paragraph 1.4).These will be acknowledged withinthree working days and a full replysent within one month. It will alsoinform the complainants theprocedure to follow if they stillwished to complain to the CRE. Areview of any complaints will beincluded in the Annual Report.



TARGET TASK ACTION BY

1. Monthly Meeting of working group – preparation of draft Working Grouprace equality scheme (RES)

2. Quarterly Report progress to Chief Executive and Council Chair

3. March 2004 Publish draft RES Working group

4. March 2004 Identify and procure training for working group Working group/Chair

5. March 2004 Discuss arrangements with Directors with ‘high/moderate’ Working grouparea for: monitoring; publication of assessment; consultationand monitoring reports; ensure public access to informationsummaries, and wider/specialised staff training.

6. April 2004 Complete RES consultation Chair

7. May 2004 Publish summary of one to one discussions with key staff. Schneider-Ross

8. May/June 2004 Develop specific training modules for working group Schneider-Ross/and staff Working Group

9. July 2004 Publish RES Chair

10. Quarterly Meeting of working group to monitor progress/problems Working group

11.August 2004 Begin training on: impact assessment; effective Schneider-Ross andimplementation of RES (embedding RES in policy making; Training and Developmentscreening, monitoring, consulting etc); general training on OfficerRES for staff

12.August 2004 Seminars for Senior Staff Schneider-Ross

13.August 2004 Staff Survey – data for analysis/monitoring Human Resources Department

14. September Analyse 10% of staff appraisals Human Resources 2004 Department/

Working Group

15. May 2005 First annual review of RES Working Group

energywatch Action Plan,1st Year

Annex A



ANNEX B

Race Equality Scheme– 2004/2007

Action Plan Timetable

The following timetable summarisesthe main tasks identified byenergywatch which will be addressedyear by year over the three yearperiod of the RES. The first yearAction Plan (attached) sets out thetarget dates, main tasks, andresponsibility for delivery of the tasks.

Year one

Implement training for all staff ontheir responsibilities under theRace Relations (Amendment) Act2000.

Design and implement training onscreening, impact assessment (andadverse impact assessment),monitoring, consulting etc.

Establish policy and procedures onthe screening process.

Develop information strategy(including method of targetingminority communities to identifytheir information requirementsabout our services)

Screen all new policies andfunctions.

Review implementation of schemeon completion of first year.

Report progress to Councilquarterly, six monthly and annually.

Prepare next year’s action plan.

Year two

Complete screening assessmentwith Directors on all high priorityschemes.

Carry out screening assessmentwith Directors on all mediumpriority functions and policies.


Sweep up any outstanding trainingfrom year one.

Review implementation of schemeon completion of second year.

Report progress to Council at theend of second year.

Prepare next year’s action plan.

Year three

Carry out screening assessmentwith Directors on all low priorityfunctions and policies.

Review functions and policiesconsidered ‘not relevant’ forrelevance.


Report progress to Council at theend of third year.

Review the scheme.



ANNEX C

Operation Functions

High relevance to theGeneral Duty

campaigning (better billing, mediaetc)

advocacy

complaint and enquiry handling

stakeholder liaison

reachout (engaging withconsumers)

corporate strategy

fuel poverty strategy

information leaflets (inc. pricecomparison sheets)

dissemination of research analysisinternally and externally

Medium relevance to theGeneral Duty

carrying out research and dataanalysis

forward work programme

media reports (comms)

internet (currently under review)

publish annual report

Low relevance to theGeneral Duty

political lobbying

company liaison

policy liaison

publication of complaints statistics

provision of guidance/goodpractice

competition policy

market structure

information required fromcompanies



ANNEX D

Support Fuctions

High relevance to theGeneral Duty

recruitment and selection policy

training and development

pay policy

staff welfare

appraisal policy

code of conduct

equal opportunities policy

grievance procedure

disciplinary procedure

probation policy

appointing and supporting of laycommittees

procurement procedures

race equality scheme

freedom of information act

disability discrimination act

staff transfers and secondmentpolicy

Medium relevance to theGeneral Duty

contracts of employment

flexible working arrangements

Low relevance to theGeneral Duty

financial management

respond to NAO requests

internal audits

data protection compliance

employment regulations

health and safety policy andprocedures

accommodation and estate matters

it and telecoms policy

records management system

welsh language act

freedom of information act

disability discrimination act

risk management policy

agree MOU with OFGEM andkeep it under review

relocation policy

annual leave

staff handbook

support to council



race equality scheme 2004 - hcpc · energywatch race equality scheme ... assessing and consulting...

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