Workforce progress report 2021

1. Eliminate unlawful discrimination, harassment, victimisation, and other conduct prohibited by the Act.
   • Advance equality of opportunity between people of different groups or protected characteristics. Protected characteristics are defined as follows:
   • age
   • gender
   • gender reassignment
   • ethnicity
   • disability
   • marriage and civil partnership
   • pregnancy and maternity
   • religion or belief
   • sexual orientation.
2. Foster good relations between people from different groups.

The equality duty is about integrating consideration of equality and good relations into day-to-day business. It means organisations need to look at how they can positively contribute to the advancement of equality and good relations. It requires these considerations to be reflected into policies and the delivery of services, including internal policies, and for these to be kept under review. Within this report we reflect on the progress we are making.

The mainstreaming of EDI through all our work is a priority for us. In 2018, we set up an EDI Steering Group to oversee and monitor our progress in achieving this.

During 2021 the group continued to:

• provide operational oversight of our work to make sure EDI is integrated into our core activities, as set out in our EDI roadmap
• agree measures and review performance against our annual EDI action plan, which sets out the activity that we are taking forward to support the Corporate Strategy 2021–2024.

Our EDI work is linked to our staff values:

• Independent
• Professional
• Fair
• Inclusive
• Progressive.

To help to describe our work to develop a fully inclusive culture and a diverse workforce, this report is structured in three sections. It builds on our report from 2020.

Organisation

As an organisation, we expect the law firms we regulate to create and champion an equal and diverse culture, so we need to make sure we do the same. We expect our staff to consider EDI throughout their work, whatever their role.

Labour market

Our offices are based in Birmingham and London and our workforce is broadly representative of the labour market in London. According to the ONS Census 2011, England and Wales, Black, Asian and minority ethnic workers made up 8.3% of the West Midlands workforce and 20.2% in London.

Given that most of our roles are based in Birmingham, the workforce data for ethnicity can be seen to be more reflective of the ONS data for London with, for example, 25% of our workforce (172 people) being Black, Asian and minority ethnic. There has been little change in the overall diversity profile of our staff over the last few years. We continue to work on areas where data suggests we have more to do to make sure there is diversity at every level in the organisation.

Roles at the SRA

Our staff grading is structured in the following way:

• A–D: non-management roles
• E–I: specialist and management roles
• J–L: heads of business units and directors. Leadership and senior management roles are included at this level.

All data is taken as of 31 December 2021. Please note, larger percentages have been moved to the nearest whole number, while smaller percentages may show more detail. Where data reflects small numbers, we have not reported them in case individuals are identifiable. In some cases, the data in this report will be presented in line with the staffing structure to express key points.

From the beginning of a person’s interaction and engagement with us, we believe it is important that we share our commitment to EDI. We want to encourage applicants to be individuals who are proud of their diversity, promoting equality of opportunity.

We included a statement on our jobs pages about bringing your whole self to work and celebrating differences to encourage greater diversity of applicants and discourage non-disclosure. This year we have also reviewed and updated our recruitment policy with greater and clearer emphasis on our EDI commitment as one of the guiding principles.

During 2021, we continued to look at the materials used in our management essentials training, in particular:

• incorporating the use of CVs from diverse ethnic backgrounds
• including personal statements that disclose sexual orientation and disability.

These are designed to be reflective of the real makeup of applicants and help us to train and support best practice.

We also worked with specific business areas to make sure we had balanced gender panels for reviewing selection outcomes to create greater diversity of thought.

We provide job application resources through Potentially (formerly we used Fair Hiring Project). This is so all interviewees have access to a range of learning materials designed to help candidates to develop skills, insight and confidence before they are assessed at interview. This helps level the playing field for every single person invited to interview and we continue to get good feedback on the learning resources.

Diverse talent acquisition continued to be a key focus for 2021. We reviewed our executive search and selection firms supply chain, creating a small panel of agencies who can deliver quality hires for the most senior roles. This helped support us with our desire to access talent within traditionally underrepresented groups. Throughout that review, EDI was a heavily weighted selection criterion in terms of the organisation's commitment to this and the service they offer.

Established a year earlier, our staff EDI working group continued to bring together staff – at all levels – to support our commitment to a truly diverse workforce. They have helped us to develop specific actions that, we hope, will see meaningful improvement across targeted areas. And, importantly, we measure the recruitment process at each stage by grade and by characteristic.

In 2021, we undertook a comprehensive review of our internal EDI training and developed a new framework and programme of work. This led to us launching a new ‘Conscious Inclusion: equality, diversity and inclusion in action’ foundation module for all staff in January 2022. We will continue with this work in 2022, covering areas such as reasonable adjustments.

2021 also saw us launch two new spotlight modules for all staff, on unconscious bias and being an ally.

Our wider EDI work in 2021 included our new Equality Impact Assessment (EIA) framework, supported with a new elearning module providing practical examples and tips to help undertake an EIA.

Personal and professional development remains a key part of our learning and development offering. In 2022, we will be looking at the development of an Aspiring Managers Programme and a Mentoring Scheme. Both of these we hope will help address underrepresentation of particular groups in our leadership and management populations.

There was a positive response to the EDI related questions in our 2020 staff engagement survey. In response, we continue to work to further identify where we can improve and future staff surveys will feed into our thinking.

To bring policies to life and empower managers to embrace our inclusive culture, we have made EDI a key part of our leadership development activities. This includes a review day of reflection on our EDI work and next steps.

The Stonewall Workplace Equality Index is a benchmarking scheme where employers can assess their achievements and progress on Lesbian, Gay, Bisexual and Trans (LGBT) equality in the workplace. In 2021, we came 28th in their list of the Top 100 LGBT-inclusive employers and our work was recognised with a Gold Award.

We reviewed and updated our internal EDI policy this year. This which covers all aspects of our work to create an inclusive culture where everyone is treated dignity and respect and feels able to bring their whole selves to work. It sets out the responsibilities we all have to create and maintain a safe working environment, for our staff and our customers. One that is free from discrimination and bullying, and foster a culture where staff feel able to raise any concerns.

Alongside this, we also updated our Transitioning at Work policy to support our trans colleagues. And reviewed our approach to our dress code, security passes and staff records to make sure our staff feel able to express their gender or non-binary identity at work.

Our networks, established and run by staff, continued to share ideas and collaborate on events and initiatives throughout 2021. They each have an internal intranet page to share messages and raise awareness.

A quarterly cross-network meeting also provides a good opportunity to support working together, helping to share ideas and best practice.

Highlights from 2021

Our senior management team sponsor individual networks, taking a keen interest in and supporting the work of the network. We also have Board members who sponsor specific networks.

REACH (Race, ethnicity and cultural heritage) – promotes racial equality and celebrates a diverse staff community

The network held regular catchups and question and answer sessions with senior management, as well as reintroducing their popular podcast club to keep colleagues informed and engaged.

The highlight of their Black History Month celebrations was to invite journalist and writer Mike Gayle, to talk about his experience as a black writer. The network will continue to develop its work to promote race equality in 2022.

Access Ability – promotes equal opportunities and provides support around disability, health conditions and neurological differences

Network members regularly posted content on their intranet page and social media to promote understanding, acceptance, and support for people with invisible disabilities and neurological differences. They have delivered internal sessions to promote neurodiversity inclusion in the workplace, focusing on autism and ADHD.

In recognition of Learning Disability Awareness Week, the network arranged a talk with two senior representatives of University of Birmingham. This focused on improving visibility and inclusion for those with learning disabilities who are studying law and wishing to join the profession. They also heard first-hand experience of what it is like to work in a law firm with a learning disability.

The network also hosted campaigning barrister Christina Warner who talked about her sight loss condition and her work to improve visibility of disabilities in legal services. This was to celebrate Disability History Month and International Day of People with Disabilities with the theme of invisible disabilities.

NOW – Network of Women - promotes gender equality and supports women in our workplace

To mark World Menopause Day, the network continued their work to make menopause a mainstream conversation. Julie Denis, a menopause coach and consultant, delivered a ‘lunch and learn’ session for staff, with law firms joining us for the event.

The founder of Tiger Law, neurodiversity advocate and feminist lawyer, Vanessa Challess, joined us for an event. Here she shared her story of working as a woman in a traditional law firm and setting up her own innovative and inclusive law practice.

Our NOW and PridePlus networks also marked 16 days of activism against gender-based violence – a UN led campaign. We also welcomed Dr Jasna Magić from Against Violence & Abuse to talk to staff about domestic abuse from the perspective of LBT+ women.

The NOW network held a panel discussion, including trans women, and heard from our Mental Health First Aiders about how we can support LGBTQ+ colleagues.

PridePlus – promotes equal opportunities for LGBTQ+ colleagues and provides confidential support

This network was active in promoting discussion about a whole range of topics under the LGBTQ+ umbrella. This included exploring the experience of the Bi community, discussing how to support non-binary colleagues and understanding the challenges increasingly faced by the trans community.

We held events about the work of Just Like Us, a charity supporting young people in schools and learnt about the experiences of LGBTQ+ people suffering domestic abuse.

PridePlus also worked in partnership with other networks to celebrate International Women's Day. For this they hosted a talk with Rachel Reese from Global Butterflies, which also raised issues such as mental health.

Mental Health First Aiders – trained colleagues who provide support and signposting on mental health and wellbeing

The network organised a speaker event with organisational psychologist, Nicola Butcher. The talk explored how we can use self-coaching techniques to respond to negative thoughts in the workplace to build resilience and productivity.

Working Parents – for working parents to share ideas, information and support.

The network delivered programmes of activities and events on topics of interest to parents. It also encouraged a sense of community for parents of children of all ages through regular blogs and discussion groups. In addition, it assisted with our development of a new hybrid way of working.

iCare – offers support, practical advice and information for carers of adults or children

The network organised an event with Sharon Grey from a residential care home that covered operating during the pandemic, leading and recognising the team and caring for residents. The network also had a talk from Christine Lowthian on her career researching into the causes of dementia and possible treatments. The event also looked at developing services for people with dementia and their careers in both the voluntary and health sectors in a range of roles.

Charity Working Group

As we could not have some of our usual charity events in 2021, due to the Covid-19 pandemic constraints, the group had to take different approaches for fundraising. Overall, we raised £2,000 for our charity, Mind. One of most successful events was a virtual Travel to Tokyo event, where more than 200 people across the organisation took part, raising around £860.

Staff faith events

We also continued to organise staff faith events during 2021. These encourage staff from all religions and backgrounds to come together and celebrate as one. Virtual events were held for Vaisakhi, Passover, Eid, Diwali and Christmas.

Our Christian network also hosted a weekly virtual network prayer meeting for anyone that wished to join or to submit a prayer request for themselves, family, or friends.

Our SRA Allies offer all staff the chance to show support for colleagues as part of their commitment to creating a diverse and inclusive workplace. They do this by getting involved in events and initiatives aimed at creating an environment where all staff are free from discrimination and able to be open about who they are. This helps to create a working environment in which staff can fulfil their potential, regardless of their characteristics.

In 2021, we created and launched our Being an Ally elearning, as well as a series of ally guides. The elearning aims to build on the work of our Allies network to show support to all our colleagues, whatever their background.

We also changed our SRA Allies logo to further promote the scheme and give it its own identity. We encouraged more staff to sign the SRA Allies pledge throughout the year.

A new Allies Champion was nominated in recognition of their work on inspiring others through sharing their own experiences and raising awareness on important issues such as intersectionality and neurodiversity.

We continue to provide a range of staff benefits which reflect our inclusive approach. Our digital platform, the Recognition Hub supports timely recognition and reward for staff for embodying our behaviours and values.

We regularly remind staff through our internal communication of the importance of celebrating good news and success. In 2021, 74% of staff were recognised via the Recognition Hub.

In addition, during 2021 we have had 1,213 Thank You award nominations, 959 (79%) of which were submitted by management. A total of 482 ecards (such as welcome, congratulation, behaviours and the SRA values) have been sent.

Following the successful trial of a Wellbeing section in our Recognition Hub, we permanently introduced this helpful resource and in 2021, 330 staff visited at least one Wellbeing page.

Our weekly news round-up highlights offers of the week and links to where staff can access further discounts and up to date information. During 2021, staff saved more than £26,000 through the discount scheme in the Recognition Hub.

Key highlights and trends

Our workforce is 63% female (444) and 37% male (261). This is compared to 61% female (428) and 39% male (269) in 2020. The government employment figures for 2019 show that women made up 48% of the workforce in England, Scotland and Wales.

Of those promoted in 2021, 56% (31 people) were female and 44% (24 people) were male. This compares to 66% (44) and 34% (23) respectively of those promoted in 2020.

For grades J–L, there was a decrease in the number of external female applicants. In 2020, 51% of external applicants were female, this decreased to 29% in 2021.

Flexible working is an area that continues to show a significant gender split. We encourage and support colleagues to work flexibly. The number of flexible working requests increased from 42 to 51 in 2021 following the shift to remote working during the pandemic.

Out of 444 female staff members, 38 applied for flexible working in 2021 which equates to 8.6%. Out of 261 male staff members, eight applied for flexible working in 2021 which equates to 3%. Therefore, females are approximately three times as likely to apply. s

Gender Pay Gap

We published our Gender Pay Gap figures, which compare positively with the national one of 15.4% (ONS 2021).

The mean pay gap is the difference between hourly earnings for men and women, taking the sum of all hourly rates divided by the total number of men or women in the sample.

The median pay gap is the difference between the midpoints in the ranges of hourly earnings between men and women. It takes all salaries in the sample, lines them up in order from lowest to highest, and picks the middle-most salary.

The figures reflect the female/male profile across the organisation, and the presence of more men in the senior management teams. In addition, a higher proportion of females work part-time in lower-level roles.

In 2021, both the mean and median bonus gap have decreased compared to 2020, showing an inverse median bonus gap. That is, the proportion of females receiving a bonus exceeds the proportion of males, particularly at a senior level.

We are committed to reducing the gender pay gap and have an action plan in place.

This includes:

• an ongoing review of our reward strategy and how we recognise staff
• continuing to review how we recruit, retain and promote females into senior roles
• reviewing our policies, processes and practices to provide an environment where everyone can flourish.

Key highlights and trends

The largest proportion of our staff (32%) are within the 35–44 age bracket, followed by those in the 25–34 age bracket (25%). Just under a quarter of our workforce (24% – 172 staff) are aged 45–54, 13% (94 staff) are aged 55–64, 3% (24 staff) of our workforce fell in the 16–24 age bracket and 2% of staff were aged 65 and over.

All age brackets were represented across all pay grades with the exception of 16–24 year-olds. Within grades J–L there was no representation from this age bracket. This has not changed since 2016.

We promoted 55 colleagues during 2021. Please refer to the table below displaying comparison for promotions between 2020 to 20211.

In 2021, 36% of external candidates were in the 25–34 age bracket. This compared to 38% in 2020. Although there is a 2% decrease, this suggests that we continue to be attractive to external candidates within this age group.

A combined total of 35% (30 staff) of successful internal applications were from those within the 16–24 and 25–34 age brackets.

Key highlights and trends

The term Black, Asian and minority ethnic includes any member of staff who self-identifies their ethnicity as anything other than White.

Our largest ethnic minority group making up 20.4% of the workforce is Asian. However, the proportion of Black, Asian and minority ethnic staff continues to be lower in the middle and senior management grades than in the less senior grades. This is the case with many organisations and is an area where we want to see improvement.

Of those promoted in 2021, 40% were Black, Asian and minority ethnic (compared to 27% in 2020). These employees also made up 48% of internal applications, which is an increase from the previous year from 32%.

Government employment figures for 2019 showed that 13% of the workforce in England, Scotland and Wales were from a Black, Asian or minority ethnic background and 87% were White. Of the groups making up the Black, Asian and minority ethnic category in relation to the UK workforce:

• 7% are Asian
• 3% are Black
• 1% Mixed/Multiple background
• 2% other minority group.

We welcome the progress but know we have more to do. We will build on our work to date to make sure our people have every opportunity to develop their careers with us.

Key highlights and trends

In 2021, 9% of our workforce (63 people) have declared that they have a disability. This is up from 8% in 2020.

Although the numbers are small, the proportion of external applicants applying who declare a disability is steadily increasing. In 2021 it was 7% of external applicants, compared to 5% in 2020, 4% in 2019 and 3% in both 2018 and 2017. We also saw that 7% (8 people) of new starters in 2021 had a disability, which is an increase from 5% in 2020, 4% in 2019 and 3% in 2018.

There has been an increase from 7% to 9% of those at grade J–L reporting as having a disability.

According to the Government, 14% of the workforce declared a disability and 20% of the working age population in 2021.

Key highlights and trends

Within our workforce, the largest group of staff identified as those saying they have no religion, 35% (244 people). The second largest group are Christian, 33% (234 people).

Of other groups, 8% (58 people) identified as Muslim, 8% (54 people) as Sikh and 3% (18 people) as Hindu. The representation of Hindus increased by one percentage point. The representation of Muslims and Sikhs remained unchanged at 8%.

Of staff working in grade E–I roles, 36% (188 people) identified as Christian, 33% (173 people) said they had no religion, 8% (43 people) identified as Sikh and 7% (34 people) identified as Muslim.

For staff working in grade A–D roles, 28% (33 people) identified as Christian, 28% (33 people) said they had no religion, 19% (23 people) identified as Muslim and 7% (8 people) identified as Sikh.

The majority of staff working in grade J–L roles, 59% (38 people) have no religion. There were also 20% (13 people) who identified as Christian, 3% (two people) who identified as Buddhist, 2% (one person) who identified as Muslim and 5% (three people) who identified as Sikh.

Twenty-seven per cent (15 people) of those who received a promotion identified as Muslim, Sikh or Hindu.

Key highlights

Three per cent (21 people) disclosed their sexual orientation as gay/ lesbian or bisexual.

From external applicants, 6% declared that they were gay/ lesbian or bisexual, compared to 5% in 2020.

Gay and bisexual members of staff were represented across all grades.

An estimated 2.7% of the UK population aged 16 years and over identified as lesbian, gay or bisexual (LGB) in 2019, an increase from 2.2% in 2018.

A diverse workforce increases productivity and creativity, which will have a positive impact on the organisation. Therefore in 2021, we asked staff to review and update their personal diversity data held on our HR system. These questions help us to check that we are being fair and that all staff are represented and supported.

Please see below several charts showing our workforce data for parental occupation, parents’ attendance of university and school attendance for the years 2020 and 2021.

There is a greater proportion of staff from a professional parental background compared to the general population and the Financial and Professional Service sector (FPS).

In 2021, 44% of staff are from a professional background, compared to 37% nationally and 69% in the FPS sector.

From an intermediate background, there were 18%, compared to 24% nationally and 22% in the FPS sector.

Thirty-eight per cent of staff are from a lower socio-economic background, compared to 39% nationally and 29% in the FPS sector.

Twelve per cent of staff had one or both of their parents attend university, whereas 33.3% did not have parents who attended university. The remainder preferred not to say.

In 2021, 4.1% of staff attended an independent or fee-paying school, which compares to the national average of 7.5% of the workforce attending an independent or fee-paying school.

Of staff attending a non-selective state-run or state funded school, 33%  were between the ages of 11 and 16.

We presented our internal and external work around social mobility to our internal staff networks and invited the Social Mobility Business Partnership to talk to us. They work with students from lower socio-economic backgrounds to deliver a work insights week and we deliver a session for that each year. It is the first time we have had an event in relation to social mobility and the feedback was well received about the event. We will continue to raise awareness of the benefits of asking these questions during 2022 to improve response rates.

Caring responsibilities

Of staff who responded, 20% declared that they are the primary care giver for a child under 18. Compared to 2020 this is a 6% increase. Five per cent of our staff look after or care for someone with long term physical or mental ill health caused by disability or age (up 1% from 2020).

Although we have good diversity in our workforce, we don’t when it comes to more senior positions. That isn’t acceptable and we want to make changes to increase diversity at every level in the organisation.

We will carry out a programme of work to better understand the reasons behind the low representation of staff from specific groups in senior positions, in particular colleagues from Black, Asian and minority ethnic backgrounds, and what new measures we can put in place to make the difference we all want to see. This will include learning from best practice and working with leaders and experts in this area to identify how to successfully increase diversity, particularly in senior teams.

Our Board is keen to see real improvements in this area. As well as offering insight and inputs on how to reduce the gap, it will be assessing long term progress on this issue.

Leadership

We continue to use the employee lifecycle approach to support our leadership. We are developing a revised suite of HR related management information to inform the senior management team better and to aid role modelling inclusive leadership behaviours.

We have revised our approach to developing our leaders, introducing a leadership pathway taking the journey of leadership from being an aspiring manager to executive leader. This pathway will introduce fully inclusive mentoring support, tailored for underrepresented groups of staff.

Resourcing

We will continue to review and update diversity content in recruitment marketing materials and available online platforms, as well as any relevant training content. We will also analyse recruitment data to identify trends and make positive changes.

In addition, we will undertake a full equality impact assessment on the recruitment and selection policy, to identify any barriers and make any necessary changes to the policy.

Learning and development

In 2022, we will be looking at the further development of an aspiring managers programme and a mentoring scheme, both of which we hope will help address underrepresentation of particular groups in our leadership and management.

We will be reviewing our suite of EDI elearning modules to embed unconscious bias throughout all our learning.

We will continue with this work in 2022, including a focus on reasonable adjustments.

Other initiatives

We will continue to review our progress against our staff survey and action plans, including those areas relating to EDI, effective leadership and managing change.

Our EDI working group have continued to work on the following four objectives:

• Recruitment – to make sure the process is fair, impartial and based on merit and to identify where unrepresented groups are being rejected at all levels to facilitate next steps to address potential issues.
• Talent – develop a pipeline of talent throughout our organisation that encourages opportunities for all staff, where appropriate to be identified by providing a range of tools that are fully inclusive.
• Data – encourage an environment for all staff so that they feel confident to fully complete our annual diversity data collection.
• Intersectionality and inclusivity – determine what intersectionality means to our organisation alongside satisfying the criteria of our current work on the Stonewall Workplace Equality Index.

During 2021 we continued to conduct equality impact assessments on our polices and some of our training programmes. These assessments make sure our processes and decisions are fair, meet the needs of our people, and do not inadvertently discriminate against any protected groups. We will be completing equality impact assessments on relevant HR policies, where appropriate.

We will continue with our membership as a Disability Confident level two employer. This will involve further training for line managers, some of which can be incorporated into the recruitment and selection training.

We are working closely with Stonewall on developing our next application for the top 100 employers in their annual index.

We will investigate the reasons behind the low representation of staff from a Black, Asian and minority ethnic background in senior positions, and what new measures we can take to address the problem. This will include learning from best practice and working with leaders and experts in this area to identify how to successfully increase diversity in senior teams.

We continue to build on our experience over recent years and particularly post Covid-19 pandemic. We have introduced hybrid working by implementing a greater degree of home working for all staff and increasing the scope for flexible working hours.

We will continue to review our wellbeing strategy to provide a healthy, agile, inclusive, and purposeful environment. One where individuals can be supported to take responsibility for their own ideal work/life balance.

Reward

The findings within our Gender Pay Gap report will allow us to engage with staff to make progress in this area.

We will continue to use the Recognition Hub more widely to celebrate and communicate success with others.

We will promote a greater level of peer-to-peer nomination and recognition and encourage nominations that recognise achievement in line with our behaviours and values.

Networks

We will build on network sponsorship work to increase visibility of our senior management and the wider leadership team in actively endorsing and promoting each of the networks. This will help to embed and strengthen their position and encourage further diversity of thinking and new ideas. In turn, we believe this will have a positive impact on attraction and retention of those with a protected characteristic.

We will also continue to endorse and promote our staff networks further, and encourage joint working to provide useful information, videos and online intranet content to support all staff.