Shape our equalities commitment

Chris Elliot, Management Committee Chair

I am proud to be the Chair of an organisation that embraces equality, diversity and inclusion at its core. The Association understands that people are not defined by their age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation. They also understand that while people can share one or more characteristic, they are all individuals and their needs are different.

The Management Committee have a clear commitment to equality, diversity and inclusion and we work hard to embed a positive inclusive culture in everything we do and the decisions we make.

Clive Douglas, Chief Executive

I am delighted to introduce our Equality, Diversity and Inclusion Strategy and to thank everyone who contributed to it. Our strategy underpins our overall vision (local people, local control) and strategic objectives.

We have seen an increase in diversity within the community we operate, and Glasgow as a whole. The increase in diversity has also seen a change in circumstances and needs of our customers.

The complexity of needs has also changed over the last few years, with societal and economic challenges (such as, economic inequalities, social isolation, and in-work poverty) having a significant impact on those already facing barriers due to their age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation.

We remain committed to being a flexible and adaptable organisation, to help us meet these changing needs and contribute to making a diverse and inclusive community.

We are committed to providing excellent services and homes for all our customers. We know that to do this we must ensure that our customers have a meaningful voice in what we do and how we do it, and ensure that all decisions we make consider equality, diversity and inclusion (EDI) of our customers and stakeholders.

The purpose of this strategy is to reflect on the work already carried out, identify what works well and build on these areas, and identify opportunities for improvement. The strategy will also set out meaningful and achievable outcomes for the next 3-years.

£ How was the strategy developed?

We developed this strategy by listening to what our customers think about us now and how they think we could improve. We used information gathered from our customers, Performance Improvement Network (PIN), Management Committee and employees to build this strategy and action plan.

£ What do we mean by EDI?

We believe that EDI is not just about the nine protected characteristics that are set out in legislation, but also about ensuring no person or group feels marginalised, and that they are able to be heard and access services as they need.

Our approach to EDI recognises that everyone is different and what one person needs doesn’t mean everyone needs the same service or support. We recognise the positive impact having a diverse and inclusive community and workplace has, and we embrace the benefit it brings.

Equality is about ensuring that every individual has an equal opportunity. This is not about treating everyone the same but providing a fair access to the same opportunity, specifically to those with a protected characteristic.

We also recognise that people will identify with the nine protected characteristics, and these can intersect. Everyone has their own unique identity and experience of discrimination.

This strategy will provide a framework for how we will improve equalities, diversity and inclusion, to maximise accessibly of our homes and services, boost engagement with under-represented groups, and to improve overall customer satisfaction.

£ Regulatory & legal obligations

This strategy builds on our legal and regulatory requirements as an employer and social landlord.

Under the Equality Act 2010, we must:

- eliminate discrimination, harassment and victimisation

- advance equality of opportunity between people

- foster good relations between people

Under the Housing (Scotland) Act 2010, we must:

- recognise individual needs and rights

- treat everyone fairly and with respect

- provide fair access to housing and services

What is the Housing (Scotland) Act?

This piece of legislation has evolved over the years to ensure that not only improvements to housing quality and availability of social housing but to ensure tenants’ interests are protected. The Act has previously introduced the Scottish Housing Charter and established the Scottish Housing Regulator.

The Housing (Scotland) Act 2010 established the Scottish Social Housing Charter, which sets out outcomes expected for registered social landlords. The Charter includes the following equalities outcome:

Every tenant and other customer has their individual needs recognised, is treated fairly and with respect, and receives fair access to housing and housing services.

What is the Scottish Housing Charter?

The Charter is 16 expected outcomes and standards that all social landlords should achieve. Social housing landlords’ performance is monitored against these standards by the Scottish Housing Regulator. A full copy of the Charter can be found on the Scottish Government website (www.gov.scot).

The Scottish Housing Regulator (SHR) sets out expectations for all registered social landlords within their regulatory framework; this includes the following in relation to equality and human rights:

Have assurance and evidence that it considers equality and human rights issues properly when making all of its decisions, in the design and review of internal and external policies, and in its day-to-day service delivery.

To comply with these duties, landlords must collect data relating to each of the protected characteristics for their existing tenants, new tenants, people on waiting lists, governing body members and staff. Local authorities must also collect data on protected characteristics for people who apply to them as homeless.

Who is the Scottish Housing Regulator? They are an independent organisation who monitor landlords’ performance against expected outcomes and regulatory requirements. Their role is to protect the interest of tenants and others who use landlord services. More information about their role can be found on their website (www.housingregulator.gov.scot).

In addition to the above legislation, we have embedded the Human Rights Act 1998 (HRA) as part of our EDI strategy. Human rights are the basic rights and freedoms that belong to everyone. They mean that everyone should be treated fairly, with dignity and respect. The HRA sets out 16 human rights, how these rights must be respected by public bodies and how individuals can seek justice if these are breached. There are 3 rights that we must consider as a social landlord:

§ Right to a fair trial (article 6): Everyone should be given the opportunity to participate effectively in any hearing of their case and present their side. To achieve this, we will (1) communicate any decision relating to your tenancy clearly in a format you can understand, (2) provide reasons for any decisions taken and (3) provide you an opportunity to appeal decisions made.

§ Right to respect for private life, family life and the home (article 14): Everyone has the right to access and live in their home without intrusion or interference. To achieve this, we will (1) respect how people choose to live their life, (2) only intervene where this negatively impacts on safety or security of others and (3) use personal information for the purpose it was collected and adhere to Data Protection legislation.

§ Prohibition of discrimination (article 8): Everyone has equal access to the other rights contained in the HRA. To achieve this, we will (1) provide services free from discrimination, (2) be aware of barriers faced by those with a protected characteristic, and (3) remove barriers faced to allow equal opportunity for all.

The Scottish Housing Regular (SHR) is required to take proactive steps to ensure the protection of children’s rights in their decision making and service delivery, under the United Nations Convention on the Rights of the Child (Incorporation) (Scotland) Act 2024 (UNCRC Act). While the Act does not identify registered social landlords as a required body in terms of reporting, we consider it important to proactively embed this approach in our EDI strategy.

Strategic Alignment

Our vision, values and strategic objectives focus on delivering services that reflect the needs of our customers and local community. To be able to do this we need to know who our customers are and what they need. To help achieve this, we have a Customer Engagement Strategy and Action Plan.

Our current action plan runs from 2025 to 2028, and the outcomes are aligned with our equalities commitment, they are:

Outcome 1: Communicate with our customers in a way that suits them.

Outcome 2: Be clear about our who we are, what we do, and how our customers can get involved.

Outcome 3: Provide a range of opportunities for customers to influence the work that we do.

Outcome 4: Remove barriers for our customers engaging with us.

To help boost our awareness of what our customers need, we conducted a customer satisfaction survey in 2025. This survey identified high levels of customer satisfaction. However, with the in-depth information supplied, we were able to dig down into key areas that have a negative impact on customer satisfaction and build an action plan to help boost satisfaction.

Our Management Committee have strategic oversight of equalities and customer engagement. Through quarterly reporting, the Management Committee are provided with regular updates to action plans and any significant changes.

The Management Committee also have strategic oversight of how other Association activities impact on Equality and Human Rights, via the reporting requirements. Each report submitted must include any Equality and Human Rights implications for consideration by the Management Committee.

Policy Alignment

Equality and Human Rights are considered whenever a policy is introduced or reviewed. Built into our policy template, our Equality and Human Rights Impact Assessment looks at any impact the policy may have on equality and human rights and identifies any mitigation where that impact is negative.

We have dedicated policies and procedures that address matters linked to possible harassment issues. They include:

§ Dignity At Work – Workplace policy to provide expected behaviours from employees and a framework to address any harassment in the workplace matters.

§ Anti-Social Behaviour Policy – Tenant policy to provide a framework to address any harassment matters between tenants.

People Alignment

Annual training is carried out with employees and Management Committee, to embed our commitment to equalities. The training also ensures that everyone is aware of and understands their own personal responsibilities in terms of equalities, in relation to the legislation, regulations and Association standards.

We provide translation and interpretation services to ensure that we can communicate with our customers who require support in this area.

Action Plan

In 2023, we launched our revised Equality and Human Rights Policy and Action Plan. Within this plan we identified 6 key objectives we wanted to achieve within 3-years of implementation. Below is a summary of our key achievements from these objectives.

1. Raise awareness of our equalities commitment.

We carried out a promotional programme, ensuring our equalities commitment and services were shared with our customers.

We included our equalities commitment in our sign-up pack, ensuring all new tenants were aware of the commitment from the start of their tenancy.

2. Actively assist equality groups within the local community to benefit from our services.

We linked in with a variety of groups within the local community to provide support and assistance via our Advice and Learning Centre (such as, YMCA and Action for Children).

We hosted a diversity event, where local partners were invited to attend. The event was open to all from the community to show them what services were available for them within the community.

3. Ensure equality of opportunity & treatment for all in relation to the employment of staff.

We revised our recruitment and selection policy and process, embedding an interview guarantee scheme for those who meet the minimum essential criteria and have a disability.

We introduced redacted applications for shortlisting purposes. Ensuring no data which could identify an individual is included (such as removal of email addresses which could identify the sex of an individual via the email address).

4. Ensure that all staff and committee are aware of our commitment to, and obligations in relation to, equality and human rights.

We carried out mandatory equality, diversity and inclusion training for all employees, PIN members and Management Committee members.

We reviewed our Equality and Human Rights impact assessment for all policies.

5. Be mindful of our equalities commitments in relation to the procurement of contractors / consultants.

We ensure contractor/consultant application forms include equality and human rights compliance.

Tender documents include an equality and diversity declaration.

6. To periodically collect, collate and analyse appropriate data, and use it to enhance our services, and assess how reflective we are the community we operate.

We carried out a tenant survey in 2023, to gather anonymised equality data. This data allowed us to get to know our customers. This data can be found in appendix 1.

Our vision for EDI, is to promote inclusion and demonstrate our commitment to equality and diversity in everything we do. We want to ensure that EDI is embraced and embedded at all levels of the Association and in the work that we do. To achieve this and our legal obligations, we will focus on the key outcomes:

1. Leadership	Ensure EDI is driven by the Management Committee and Leadership. We recognise the importance of - having Management Committee reflective of the community we operate in, to help enhance our decision making and services to our customers, including robust risk management. - robust reporting of EDI matters, to ensure we are making the right decisions for our customers. - building in EDI from a strategic level to ensure it embeds in everything we do.
2. Workforce	Ensure we have a skilled and committed workforce. We recognise the importance of - having a diverse workforce to enhance our teams and services to our customers. - knowledge and understanding of EDI matters, to boost understanding and support for each other. - listening to our colleagues about what is working well and what we might need to focus on to improve, removing barriers for our colleagues, having open communication, and support to any colleague who raises concerns.
3. Customers	Ensure our customers are heard and their needs understood. We recognise the importance of - knowing who our customers are, so we can provide better services to meet their needs and circumstances. - maximising the ability for our customers to provide feedback and engage with the work we that we do. - addressing underrepresentation in our engagement groups.
4. Services	Ensure we maximise accessibility of services. We recognise the importance of - identifying potential barriers to our services and proactively addressing these by offering a wide range of support services (such as interpreters). - raising awareness of services available, in a suitable and diverse way. - knowing who is using our services and identifying any reasons to why certain groups are not engaging with our services.
5. Policy	Ensure our policies and processes are accessible and do not create barriers. We recognise the importance of - having a robust approach to EDI impact assessments and addressing any issues raised.

We will create an outcome focussed action plan to ensure we achieve our outcomes. This action plan will be monitored by our Management Committee and managed by our Senior Management Team. Our outcomes build on the work already achieved by our last 3-year action plan.

1. Leadership

Ensure EDI is driven by the Management Committee and Leadership.

1.1. Review succession planning for Management Committee in line with equalities data.

1.2. Review reporting of EDI, setting clear performance standards and progress.

1.3. Review strategic overview of EDI matters, ensuring consideration of these matters are included in core business decisions (e.g. risk register / business plan).

1.4. Reinforce our commitment to EDI.

2. Workforce

Ensure we have a skilled and committed workforce.

2.1. Review training and development needs. Look at individual equality topics (e.g. cultural norms) to increase knowledge and understanding of our customers.

2.2. Review relevant employment policies and procedures, ensuring EDI is embedded in core policies (e.g. code of conduct / dignity at work) and our employees are heard.

2.3. Look at opportunities to become a more diverse workforce in line with equalities data.

3. Customers

Ensure our customers are heard and their needs understood.

3.1. Deepen our knowledge of our customers – who they are and what they need.

3.2. Maximise participation and engagement with customers from different backgrounds (link with Customer Engagement Strategy).

3.3. Identify any significant issues impacting our customers (e.g. ill health, poverty, etc), which are compounded by equality issues and take steps to support them.

4. Services

Ensure we maximise accessibility of services.

4.1. Identify potential barriers to our services and proactively take steps to remove these.

4.2. Maximise communication of services (in a variety of formats etc.).

4.3. Seek out opportunities to introduce new wider role services, to meet our customers’ needs.

5. Policy

Ensure our policies and processes are accessible and do not create barriers.

5.1. Identify potential access barriers to our policies and proactively take steps to remove these.

5.2. Audit our EDI impact assessments and identify any actions required.

Our community equalities data

Census – Scotland Census 2022 (electoral data set Shettleston Ward).

Tollcross – Equalities Survey 2023 (913 interviews completed).

Age	Under 16	16-24	25-34	35-44	45-54	55-64	65-74	74-85	85+
Census	15.7%	9.2%	15.1%	12.3%	12.6%	15.9%	10.8%	6.1%	2.3%
Tollcross	N/A	3.4%	16.3%	20.7%	16.5%	19.8%	14.2%	6.3%	1.9%

Disability	Yes	No
Census	32%	68%
Tollcross	34%	60%

Gender reassignment (trans status or history)	Yes	No
Census	0.54%	99.46%
Tollcross	0.80%	96.9%

Marriage & civil partnership	Never married / civil partnership	Married / civil partnership	Separated	Divorced	Widowed
Census	45.3%	34.9%	3.3%	8.8%	7.8%
Tollcross	Data not gathered as only required for employment purposes.

Pregnancy & maternity – data not available

Race	White Scottish	White Other	Mixed or multiple	Asian	African	Other
Census	80.0%	11.2%	0.9%	3.8%	2.8%	1.1%
Tollcross	75.6%	15.8%	0.0%	1.5%	4.7%	0.3%

Religion or belief	Christian	Other	None
Census	52.0%	3.6%	44.%
Tollcross	49.8%	4.6%	34.1%

Sex	Female	Male
Census	52%	48%
Tollcross	62.1%	35.9%

Sexual orientation	Heterosexual	Gay / Lesbian	Bisexual	Other
Census	87.1%	2.3%	1.7%	0.5%
Tollcross	88.0%	2.3%	1.1%	1.0%

Note: ‘Prefer not to say’ option for Tollcross equalities survey was available – making total percentage above less than 100%.

Definitions

Equality: Making sure individuals are treated fairly and given fair chances. It is not about treating everyone in the same way but recognising that different needs may have to be met in different ways.

Diversity: Valuing and managing individual differences. It is recognising and embracing the backgrounds of different people, their skills, attitudes, experiences and being open to them bringing fresh ideas and views that will enhance the organisation.

Inclusion: Creating an environment where everyone feels safe, welcomed and genuinely valued. This involves making everyone feel like they belong and the ability to fully participate in the decision-making processes which affect them.

Protected Characteristics: The legal grounds in which discrimination claims can be made. These include age, disability, gender reassignment, marriage & civil partnership, pregnancy & maternity, race, religion or belief, sex, sexual orientation.

Direct Discrimination: Treating someone less favourably than another person based on a protected characteristic.

Discrimination by Association: Discrimination against a person because they have an association with someone with a particular protected characteristic (they themselves do not need to have the characteristic).

Discrimination by Perception: Discrimination against a person because it is perceived that they have a protected characteristic.

Indirect Discrimination: A policy, practice, procedure, provision or criteria that applies to everyone in the same way but might disadvantage a particular protected group, and which cannot be objectively justified in relation to the job.

Harassment: Unwanted conduct related to a relevant protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. Any Organisation will extend this definition to include any harassment and will not be restricted to those identified as having a protected characteristic.

Sexual Harassment: Conduct of a sexual nature that has the purpose or effect of violating someone’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment, and less favourable treatment to sex or gender reassignment that occurs because of a rejection of, or submission to, sexual conduct.

Victimisation: Treating someone less favourably and discriminating against them because they have pursued or intend to pursue their rights relating to alleged discrimination, complained about the behaviour of someone harassing them or given evidence in someone else’s discrimination complaint.