Equity, Diversity and Inclusion Policy

2. Scope

This policy demonstrates our compliance with key legislation, including but not limited to the Equality Act 2010 and the Public Sector Equality Duty (PSED). It also outlines our adherence to Regulatory Standards issued by the Regulator of Social Housing and the Housing Ombudsman, such as the Consumer Standards Code of Practice 2024 and the Housing Ombudsman Complaints Handling Code 2024. In addition, it clearly reflects our alignment with the NHF Code of Governance 2020 in relation to EDI, workforce, Board functions, and the processes for Board election, selection and appointment. 

This policy applies to all colleagues including Board and Committee Members of B3Living and all its legal entities.

3. Aims and objectives

To support the delivery of our EDI vision and strategy, this policy sets out the following aims and objectives:

► To demonstrate the commitment of the Board of B3Living to achieving equity of opportunity, diversity and inclusion in all of B3Living’s activities, as well as diversity within its own composition.

► To ensure that the fundamental importance of EDI is widely understood and valued throughout B3Living, by both colleagues and customers, based on a shared understanding of how a culture of inclusivity supports progress against our corporate strategy and EDI Strategy and our broader social purpose.

► To embed a commitment to providing inclusive services that reflect the diverse needs of our residents within the organisation’s culture and operations and to ensure this commitment is embraced by colleagues at all levels.

► To demonstrate that our commitment to EDI is led by the Board, which sets our objectives and actively seeks regular assurance on how these are being delivered in practice.

► To ensure that our commitment to delivering personalised and inclusive services aligned with the diverse needs of our residents is embedded in our culture and operations and embraced by all colleagues.

► To ensure transparency in the work undertaken to meet our EDI commitments and in the progress we make against the objectives set.

► To ensure that the Board of B3Living and its Committees continuously strive to select their members from a diverse pool of people bringing a range of backgrounds, attributes, skills and behaviours needed to govern effectively.

3.1 Our people

To support our commitment to fostering an inclusive workplace culture, this section outlines how we embed EDI across the colleague experience at B3Living.

3.1.1 We aim to offer a workplace culture where inclusion is central, and where everyone feels safe and empowered to bring their full selves to work. To support this, we have implemented a range of employment policies that are regularly reviewed and updated by our Board.

3.1.2 We make workplace adjustments and ensure colleagues are confident in making adjustments for individuals who may face disadvantage across the employee lifecycle and in line with legislation and best practice.  

3.1.3 We are committed to attracting and retaining colleagues from diverse backgrounds, recognising that the diversity of our workforce is integral to delivering high-quality, personalised and inclusive services to customers and aligning with our social purpose. Our approach and objectives are outlined in our EDI Strategy and Action Plan (2025-28), which underpin our recruitment and promotion processes.

3.1.4 Our Board has access to insight into colleague views through our EDI survey, annual people report, culture audits and internal pulse check surveys (Peakon). These mechanisms ensure that colleague perspectives are considered in Board-level decision making.

3.1.5 We strive to foster a culture where it is safe and people feel empowered to challenge negative and discriminatory actions or expressions, reinforcing our zero-tolerance approach to any such behaviours.

3.1.6 We ensure that colleagues of all levels understand their responsibility to act in an equitable and inclusive way through their behaviours and day to day work. Our training and development offer supports this, helping to align colleague behaviours with the National Housing Federation (NHF) code of conduct.

3.1.7 We will empower our leadership to understand their responsibilities and to set a culture of equity and inclusion through their leadership approaches, role modelling inclusive behaviours across the organisation.  

3.2 Board Election, Selection and Appointment

3.2.1 Our Board recognises the value that a diverse membership brings to the governance of B3Living and actively seeks to achieve this through its election, selection and appointment processes.  

3.2.2 The Board aims to attract members from diverse backgrounds and attributes, reflecting the communities B3Living serves and in line with our EDI commitments. This is documented in our Board Recruitment and Tenure Policy. 

3.2.3 Board and Committee recruitment is conducted in a fair, open and transparent manner, following a competitive and merit-based process.  This process takes into account our EDI commitments, the need for diverse membership and the collective skills and behaviours needed to govern B3Living effectively.  

3.3 Delivery of services for our customers

To ensure our services reflect our commitment to EDI, this section outlines how we deliver inclusive, accessible, and customer-focused support across all areas of our work:

3.3.1 We are committed to delivering services to our customers in an inclusive and accessible way. This commitment is underpinned by a range of policies and procedures that detail how we embed EDI into our customer interactions.

3.3.2 To achieve this commitment, we:

► Assess customer needs and vulnerabilities to tailor our approach and interact in ways that best suit our customers. This is outlined in our Personalised and Inclusive Services Policy and aligns with regulatory requirements. We aim to get it right first time, providing support that reflects our customers’ diverse needs, helping them sustain their tenancy and take pride in their homes. This includes adapting to changing needs across the customer lifecycle, for example through our Independent Living offer and the support offered by our Customer Coach.

► Ensure that new homes are made available to people from all backgrounds as far as possible, while complying with the relevant regulatory, legislative and Capital Funding Guide obligations (such as affordability and ‘local connection’ criterion).

► Consider the diverse needs of our customer community in our communications and materials. This includes offering alternative formats such as different languages, large print, and easy-read versions, and adapting communication styles, for example, using phone calls rather than letters where appropriate.

► Engage with customers through our Customer Community framework to gather insights and views that inform service and policy development. We maintain a transparent relationship with our Customer Advisory Panel, supporting their autonomy and enabling them to scrutinise our work, provide constructive challenge and influence our strategic direction in line with regulatory requirements and the NHF Code of Governance and Conduct.

3.3.3 Our Board receives regular updates on the diversity of our customer base, benchmarked against data on our colleague profile, Board profile and the demographics of our operational areas (primarily the Borough of Broxbourne). This is reported on annually through our EDI Board Assurance Report, which also summarises our progress against EDI commitments and goals.

3.3.4 We work closely with contractors and suppliers to ensure that they understand and align with our EDI commitments. As part of our procurement process, we require assurance that they have policies and practices that reflect similar values and standards.   

3.4 Complaints and whistleblowing

To uphold our commitment to EDI, we have clear processes in place for addressing concerns and ensuring accountability: 

3.4.1 We have a zero-tolerance approach to breaches of this policy and our EDI commitments, and we encourage colleagues and customers to report any breaches or suspected breaches through the procedures outlined in our Complaints and Whistleblowing Policies.

3.4.2 All reported breaches are fully investigated to ensure fair and appropriate outcomes for complainants. Where failings are identified, we take steps to learn from them and implement measures to prevent recurrence.

3.4.3 As part of the internal complaints reporting process, we identify EDI-related themes and learning, which are used to inform training and development initiatives.

3.5 Equity Impact Assessments (EIAs)

EIAs are a key tool in ensuring that our services, policies, and practices are inclusive and equitable: 

3.5.1 We carry out EIAs across B3Living when introducing new services, projects, policies or processes that affect colleagues and customers. Completion of an EIA is a mandatory requirement prior to approval. 

3.5.2 EIAs are documented and stored on our internal SharePoint drive, which is available to all colleagues. All policies and strategies must include a dedicated EDI section referencing the completion of an EIA.

3.5.3 For transparency, customers may request access to completed EIAs, which will be redacted appropriately where necessary.

3.6 Definitions

To ensure clarity and shared understanding across B3Living, the following definitions are used throughout this policy: 

► Equity - Removing barriers so people can achieve their full potential, regardless of background or identity.

► Diversity - Respecting and celebrating people’s differences and treating each person as an individual.

► Inclusion - Creating an environment where everyone feels welcomed, respected, and able to contribute fully.

► Protected Characteristics - includes race (colour, nationality, ethnic or national origin), disability, sex, sexual orientation, gender reassignment, marital or civil partnership status, pregnancy and maternity, age, religion or belief. B3Living also recognises other at-risk groups, such as parents, carers, those with a gender identity which does not align with their biological sex and those from lower socioeconomic backgrounds.

► Equality Impact Assessment - A method of assessing policies, strategies, services etc. to identify potential risks of disadvantaging specific groups, and to explore ways to reduce or remove this risk. It requires the person completing the EIA to consider the impact of decisions through the lens of diverse groups.

► Employee Lifecycle - The journey a colleague takes from applying for a role to leaving the organisation. This includes recruitment, retention, promotion and exit.

► Customer Lifecycle - The journey a customer experiences from receiving a conditional offer of a property to vacating it. This includes affordability checks, sign up, repairs and maintenance, tenancy support (such as rent payments, support from a customer coach, anti-social behaviour support), and complaints.

► Reasonable Adjustments - A legal term under the Equality Act (2010) referring to changes organisations must make to ensure services and employment are accessible and do not disadvantage individuals. This may include physical alterations, additional equipment, or changes to policies, practices and procedures.

► Whistleblowing - The disclosure or reporting of information related to suspected malpractice, wrongdoing or dangers within the organisation or workplace.

4. Equity, diversity and inclusion

We are committed to treating everyone equitably, without bias, and with respect. We aim to foster a culture where people can thrive and be their authentic selves. This policy integrates EDI into our operations and applies to all parties who engage with B3Living, including our Board.

An initial equity impact assessment (EIA) has been carried out and concluded that this policy does not disadvantage any of the identified equality groups and that a full EIA is not required at this stage. However, it will be important to complete an EIA on any projects we implement because of this policy.

5. Data protection and information security

This policy will be operated in line with B3Living’s Data Protection Policy, which sets out our commitment and approach to data protection. The storing and processing of personal information about adults, children and young people is governed by the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) 2018. 

Under GDPR, customers have the right to:

► Be informed about the collection and use of their personal data.

► Receive information including B3Living’s purposes for processing their personal data, retention periods and who it will be shared with.

► Be provided with privacy information (privacy notice).

► Expect that data collected is concise, transparent, intelligible, easily accessible, and written in clear and plain language.

6. Customer voice

As this is an overarching policy, customers have not been directly consulted prior to its approval. However, customers have contributed to the development of policies that outline our approach to delivering personalised and inclusive services, and have informed our EDI priorities through surveys, case studies and complaints data.

7. Compliance

► Consumer Standards Code of Practice 2024.

► Equality Act 2010.

► Housing Ombudsman Complaints Handling Code 2024.

► Human Rights Act 1998.

► Modern Slavery Act 2015.

► National Housing Federation Code of Governance 2020. 

► National Housing Federation Code of Conduct 2022.

► Public Sector Equality Duty.

8. Health and safety considerations

We anticipate that our work under this policy will contribute to a safe and supportive work environment, enhance colleagues’ sense of belonging and positively impact colleague and customer wellbeing. Beyond these anticipated benefits, there are no immediate health and safety considerations associated with this policy.

9. Linked policies, procedures and guidance

► Adaptations Policy. 

► Allocations Policy.

► Anti-Bullying and Harassment Policy.

► Customer Influence Policy.

► Domestic Abuse Policy.

► Family Leave Policies such as: Neonatal Care Leave and Pay, Maternity and Pregnant Person Leave Policy, Adoption and Surrogacy Policy, Shared Parental Leave Policy and Parental Leave Policy.

► Flexible Working Policy.

► Menopause Policy. 

► Parental Bereavement Policy.

► Personalised and Inclusive Services Policy.

► Pregnancy Loss Policy.

► Procurement Policy.

► Recruitment Policy.

► Responsive Repairs Policy.

► Services for Older People Policy.

► Sickness Absence Policy.

► Succession and Assignment Policy.

► Tenant Management Policy.

► Wellbeing Policy.

► Whistleblowing Policy.

10. Responsibilities

To ensure the successful delivery of our EDI commitments, the following roles across B3Living have specific responsibilities: