Equality, Diversity and Inclusion Policy 

Learn Devon  ·  Connect to Work  ·  Employment Hubs 

Effective from: September 2026  |  Review date: August 2027 

Owner: Head of Employment & Adult Skills 

Aligned to: Strategic Plan 2026–2028  |  Equality Act 2010  |  DCC Equality Policy 

1.  Purpose and Scope 

Employment & Adult Skills exists to make a real and lasting difference to the people and communities of Devon — particularly those who face the greatest barriers. An unequivocal commitment to equality, diversity and inclusion (EDI) is not an add-on to that mission: it is its foundation. 

This policy sets out how Employment & Adult Skills — through Learn Devon, Connect to Work, our Employment Hub network, and Performance & Partnerships — upholds its legal duties under the Equality Act 2010, fulfils the Public Sector Equality Duty (PSED), and actively advances equality of opportunity for every person we serve and every person we employ. 

 Equality in this service means more than treating people the same. It means understanding, and actively responding to, the different circumstances and barriers that different people face — and ensuring that our design, delivery and culture genuinely level the playing field. Diversity is a strength we embrace. Inclusion is the standard we hold ourselves to every day. 

1.1  Scope 

This policy applies to: 

• All staff employed within Employment & Adult Skills, including part-time, sessional and contracted staff 

• All learners, participants and members of the public who access our services 

• All employers, partners and stakeholders we work with 

• All settings in which we operate — learning centres, Employment Hubs, employer premises, community venues and online 

1.2  Strategic Alignment 

This policy is directly aligned to: 

• Employment & Adult Skills Strategic Plan 2026–2028, which commits us to social inclusion, social mobility and serving those facing the greatest disadvantage 

• KPI 1 — Inclusive Engagement: at least 79% of participants from priority or disadvantaged groups 

• Devon County Council Equality Policy and Devon Joint Declaration for Equality 

• Devon County Council People First workforce strategy 

• Devon and Torbay Combined County Authority (DTCCA) Skills Plan 

• DWP Connect to Work IPS fidelity standards, which embed equality in supported employment practice 

• Ofsted Education Inspection Framework (EIF) — which requires leaders to actively promote all forms of equality and foster understanding across all protected characteristics 

• Matrix Standard for information, advice and guidance services 

2.  Legislative and Policy Framework 

Employment & Adult Skills operates within a clear and comprehensive legal framework for equality. Understanding these duties — and how they apply to our work — is the responsibility of every member of staff. 

Where legislation or DCC policy is updated, this policy will be reviewed accordingly. Staff must not wait for a policy review cycle to respond to changes in law — the Head of Service and line managers are responsible for communicating legislative changes promptly. 

3.  The Protected Characteristics 

The Equality Act 2010 identifies nine protected characteristics. Employment & Adult Skills is committed to eliminating unlawful discrimination and advancing equality for all nine — in how we recruit and employ staff, how we design and deliver provision, and how we engage with every individual and community we serve. 

In addition to the nine protected characteristics, Employment & Adult Skills recognises that individuals may face compounding disadvantages related to socio-economic background, geography, care experience, homelessness, offending history or other life circumstances. Our definition of equity extends to these groups — in alignment with KPI 1 of the Strategic Plan 2026–2028 and the Council’s statutory duties around Corporate Parenting and Care Experienced Young People. 

4.  Our Commitments 

The Public Sector Equality Duty requires us not merely to avoid discrimination but to actively advance equality. The following commitments set out how we do that across all aspects of our work. 

4.1  To Learners and Participants 

• Every individual will be treated with dignity, fairness and respect, regardless of any characteristic they hold 

• Access to our services will be actively designed to remove barriers — whether related to geography, language, literacy, disability, health, caring responsibilities or digital access  

• Our curriculum and delivery will be inclusive by design: differentiated to meet diverse  needs, not standardised and adapted reluctantly 

• Learner and participant support will be planned, timely and proportionate — and will recognise that need does not declare itself in advance 

• We will monitor enrolment, participation, achievement and progression data disaggregated by protected characteristic and socio-economic background, and act on disparities with urgency 

• Our Employment Hubs will provide a safe, accessible and welcoming presence for all communities across Devon — including those in rural and coastal areas who face additional barriers of geography and connectivity 

• Young people aged 16–18, those with SEND, and Care Experienced Young People will receive dedicated, culturally competent support aligned to the DCC SEND strategy and Corporate Parenting priorities 

4.2  To Staff 

• Every member of staff will be recruited, developed, managed and supported without discrimination — and in accordance with DCC HR policies and the Equality Act 2010 

• We will promote a workplace culture where difference is valued, challenge is welcomed, and harassment and bullying have no place 

• EDI will be embedded in induction, CPD and appraisal processes — not treated as a one-off training event 

• Staff will be equipped through training and support to identify and respond appropriately to discriminatory behaviour, unconscious bias, and systemic barriers in their professional practice 

• Staff who raise concerns about EDI — in relation to colleagues, participants or the service’s own practice — will be heard, supported and protected from victimisation 

• We will actively seek to build a workforce that reflects the diversity of Devon’s communities, recognising that lived experience is a professional asset 

4.3  To Employers 

• We will work with employers to promote inclusive recruitment and workplace practices — supporting them to access the talent of all Devon’s residents, including those who have faced employment barriers 

• Our employer engagement will actively challenge occupational segregation and support progression pathways for underrepresented groups 

• We will provide employers with information about their own equality obligations, and share good practice from across our networks 

• We will not work with employers whose practices are inconsistent with the Equality Act 2010 or whose culture poses a risk to the safety or dignity of our participants 

4.4  To Partners and Commissioners 

• We will share equality data openly with commissioning partners — DWP, DTCCA, NHS Devon ICB and DCC — to support joint planning, system design and investment decisions 

• We will engage EDI as a standing agenda item in strategic partnership conversations, not a compliance afterthought 

• We will contribute to Devon’s system-level understanding of inequality — using the evidence from our 9,000+ annual interactions to build a compelling picture of where gaps persist and where intervention is most needed 

5.  Inclusive Practice Standards 

This section sets the operational standards against which Employment & Adult Skills holds itself — and through which EDI commitments are translated into day-to-day practice. These standards apply to curriculum, employer engagement, communications and the physical environment. 

5.1  Curriculum and Delivery 

• All programmes will include an equality and diversity element appropriate to the context, sector and learner group 

• Teaching and learning staff will demonstrate inclusive practice in every session — as assessed through internal observation and the IQA cycle 

• Lesson and session planning will identify how learning activities are differentiated to support learners with different needs, backgrounds and characteristics 

• Assessment practices will be fair, transparent and free from cultural or linguistic bias — with reasonable adjustments applied consistently and recorded 

• Resources, materials and examples used in delivery will reflect the diversity of Devon’s communities and the wider world — not default to a single cultural perspective 

• Learner feedback will be collected in a way that allows disaggregation by characteristic, and will inform ongoing curriculum improvement 

5.2  Access and Reasonable Adjustments 

• Learners and participants will be offered a needs assessment at the point of enrolment or engagement, and at any point where needs change 

• Reasonable adjustments will be identified, planned and implemented before the individual begins their programme — not improvised during delivery 

• Adjustments may include: alternative assessment formats, assistive technology, British Sign Language interpretation, large print, adapted venue access, remote or blended delivery, and flexible scheduling 

• Where a reasonable adjustment cannot be met internally, staff will actively connect the individual to an appropriate alternative provider or support service 

• Decisions about reasonable adjustments will be documented, reviewed regularly and not left solely to the individual to chase or re-request 

5.3  Communications and Marketing 

• All marketing and communications materials will be assessed for accessibility before publication — including readability level (plain English, maximum Flesch-Kincaid reading ease of 60), colour contrast and screen-reader compatibility 

• Materials will reflect the diversity of our learner and participant community — in imagery, language and the examples used 

• Translation and interpretation support will be made available where it is reasonably required to enable access 

• Provision information will be published in multiple formats and accessed through multiple channels — digital, telephone and in person — to reflect the diverse ways in which Devon’s communities prefer to engage 

• Annual self-assessment against the Matrix Standard will include an explicit review of equality of access to information, advice and guidance 

5.4  The Physical and Digital Environment 

• All Employment Hub venues and learning centres will be assessed annually for physical accessibility and comfort for people with disabilities 

• Online platforms and digital learning environments will meet WCAG 2.2 accessibility standards as a minimum 

• Safe reporting mechanisms will be visible and accessible in all our environments — physical and digital — so that learners, participants and staff know how to raise a concern 

• Our environments will be free from any materials, imagery or language that is discriminatory, demeaning or exclusionary 

6.  Monitoring, Reporting and Impact Measures 

The Public Sector Equality Duty requires Employment & Adult Skills to collect, analyse and act on equality data — and to publish relevant information to demonstrate compliance. Monitoring is not a bureaucratic exercise: it is how we know whether our commitments are producing real change in real people’s lives. 

6.1  Data We Collect 

• Enrolment and engagement data disaggregated by protected characteristic (as declared by the individual), socio-economic background and geography 

• Achievement and qualification completion rates, disaggregated by protected characteristic — compared to the service average 

• Progression and destination data (into employment, further learning, self-employment) disaggregated by characteristic 

• Learner and participant satisfaction and feedback scores, disaggregated by characteristic 

• Referral, conversion and drop-out rates — to identify where barriers are causing attrition before or during the programme 

• Staff recruitment, development and retention data disaggregated by protected characteristic 

• Harassment, bullying and discrimination concerns and incidents — by type, setting and resolution 

6.2  Organisational Impact Measures 

The table below sets out the specific, measurable EDI impact indicators for Employment & Adult Skills, aligned to the Strategic Plan KPIs and the PSED general duty. 

6.3  Annual EDI Report 

The Performance & Partnerships team will produce an annual EDI Report, presented to the senior leadership team each September alongside the Self-Assessment Report. This report will include: 

• Analysis of equality data across all nine protected characteristics and socio-economic groups 

• Achievement gap analysis with commentary and proposed actions 

• EDI incidents: number, type, setting and outcomes 

• Equality Impact Assessments completed during the year 

• Workforce diversity data (in liaison with DCC HR) 

• Actions taken in the year and their evidenced outcomes 

• EDI priorities for the coming year, with named leads and success measures 

The annual EDI Report will be shared with DTCCA, DWP and NHS Devon ICB as part of our system-level partnership data sharing commitments. Summary findings will be included in the service’s public-facing annual impact statement. 

7.  Equality Impact Assessment 

An Equality Impact Assessment (EIA) is a structured process for analysing whether a proposed policy, procedure, practice, service change or curriculum development could have a positive, neutral or adverse impact on people who share a protected characteristic. 

Completing an EIA is a legal requirement under the Public Sector Equality Duty where a decision or change could affect people differently based on a protected characteristic. It is not a bureaucratic tick-box: it is a thinking tool that improves decisions and reduces legal risk. 

7.1  When an EIA is Required 

• Any new policy, procedure or operational guidance 

• Any significant change to an existing programme, service or delivery model 

• Any curriculum development or decommissioning of provision 

• Any change to staffing structure, terms or conditions 

• Any significant change to access arrangements, venues or delivery channels 

• Any new commissioning or partnership arrangement that affects how services are delivered 

7.2  Who is Responsible 

The person leading the policy, programme or change is responsible for completing the EIA, supported by their line manager. The Head of Employment & Adult Skills reviews all EIAs before the relevant decision is finalised. Completed EIAs are held centrally by the Performance & Partnerships team (Appendix B provides the EIA template). 

7.3  Acting on EIA Findings 

Where an EIA identifies a potential adverse impact on any group, the responsible person must: 

• Document the identified risk clearly 

• Consider whether the proposal can be amended to remove or reduce the impact 

• Set out any mitigating actions with named leads and timescales 

• Consult affected groups where this is practicable and proportionate 

• Review the impact after implementation and update the EIA accordingly 

An EIA that identifies adverse impact does not automatically mean a decision cannot proceed — but it does mean the decision must be taken with full awareness of that impact and with genuine mitigation in place. 

8.  Roles and Responsibilities 

Equality is a whole-service responsibility. The following sets out the specific accountabilities that sit with particular roles — but no member of staff is exempt from their personal duty to uphold this policy in everything they do. 

9.  Concerns, Harassment and Escalation 

Employment & Adult Skills is committed to taking all equality-related concerns seriously — and to creating a culture where people feel safe to raise them. No-one should face disadvantage, harassment or victimisation because they have raised a genuine concern about equality. 

9.1  Types of Concern 

A concern may relate to: 

• Discrimination (direct or indirect) against a learner, participant, staff member or other individual 

• Harassment on the basis of a protected characteristic — including sexual harassment 

• Victimisation of someone who has raised an equality concern 

• A policy, practice or curriculum element that may have an unequal or unfair impact 

• Systemic barriers to access, participation or achievement for a particular group 

9.2  Raising a Concern 

Staff Concerns 

Staff who identify a concern or have a question about EDI should: 

• In the first instance, speak to their line manager 

• If the concern involves their line manager, or they do not feel comfortable approaching them, contact the Head of Employment & Adult Skills directly 

• For formal HR matters — including allegations of discrimination, harassment or bullying — contact DCC HR Direct: 01392 385555 or hrdirect@devon.gov.uk 

• In all cases, the concern will be recorded in the central EDI Concern Log (Appendix B) and acknowledged within five working days 

Learner and Participant Concerns 

Learners or participants who experience or witness discrimination, harassment or unfair treatment should: 

• Speak to their tutor, adviser or hub coordinator in the first instance 

• If they are not comfortable doing so, contact the Operations Team to request a response from a Senior Manager 

• All learner concerns will be treated with confidentiality, sensitivity and urgency 

• Learners will receive a written acknowledgement within five working days and a full response within twenty working days 

9.3  Investigation and Outcome 

All concerns will be investigated proportionately to their nature and seriousness. Investigation outcomes may include: 

• An explanation, apology or assurance from the relevant team 

• A change to practice, policy or provision 

• Disciplinary proceedings in accordance with DCC HR policies 

• Referral to the Local Authority Designated Officer (LADO) where a safeguarding element is present 

• A referral to the police where a criminal act may have taken place 

9.4  Zero Tolerance 

Employment & Adult Skills operates a zero-tolerance approach to: 

• Harassment and bullying on the basis of any protected characteristic 

• Sexual harassment — including unwanted physical contact, verbal conduct or online behaviour 

• Victimisation of any person who has raised a concern in good faith 

• Deliberate exclusion, humiliation or disrespect directed at any individual or group 

Where such behaviour is found to have occurred — from a staff member, learner, participant or employer — Employment & Adult Skills will act decisively and without delay. The fact that behaviour was ‘not intended’ to cause harm does not diminish its impact, and will not reduce the seriousness with which it is treated. 

10.  Policy Review 

This policy will be reviewed annually, with a formal review scheduled for August 2027. Reviews will be informed by the annual EDI Report, changes in legislation, DCC policy updates, inspection outcomes and staff and learner feedback. 

Interim amendments may be made at any point where regulatory or operational changes require it. All amendments will be communicated promptly to staff and recorded in the version history below.