## Ethnic Disparities And Inequality In The Uk Technical Evidence Submission In Response To The Call From The Commission On Race And Ethnic Disparities

Contact Officer 
Tom Pickup, Principal Policy & Project Officer 
Tom.pickup@londoncouncils.gov.uk 07763 783966 
Organisation 
London local government technical evidence submission is sponsored by the Chief Executives London Committee Tackling Racial Inequality Working Group. 

## Introduction & Context

1. London local authorities welcome the Commission on Race and Ethnic Disparities' initiative in reaching 
out to councils and communities to help better understand and tackle ethnic disparities and inequality in the UK. We are keen to support the work of the Commission in tackling racial disparities and we look forward to engaging with the Commissions work. We feel that there is an important window of opportunity to align our system leadership, working with the grain of our communities' appetite for progress. 
2. London is proud to be the most diverse city in the UK1 - we embrace our ethnic and cultural diversity 
which is central to our city and essential to enabling our communities to thrive and prosper. However, 
evidence suggests that people from different ethnic and cultural backgrounds continue to experience disparate outcomes alongside discrimination and exclusion. London local government recognises the importance of addressing this as part of our leadership of place and is committed to understanding what more could and should be done across our sector, and in partnership, to tackle ethnic disparities and inequality. 
 
3. This submission captures themes and evidence that has emerged through collaborative cross-borough 
working on this agenda. In addition, individual London boroughs hold more local and granular evidence which may be useful to the Commission. This submission opens with an outline of our pan-London programme that is being built to support and embed local action dedicated to improving services and tackling racial inequality. We go on to outline evidence of racial disparity from the thematic areas identified by the Commission *(education, employment and enterprise, health and crime and policing)* and posit key lines of inquiry that we believe the Commission and its partners should consider to help provide a foundation to achieve genuine change. 

## London Local Government'S Tackling Racial Inequality Programme

4. In June, in response to the resurgence of the Black Lives Matter movement and the disproportionate 
impact of the Covid 19 pandemic on Black, Asian and Minority Ethnic (BAME) communities, London Councils, working in partnership with London boroughs, initiated a pan-London programme to tackle racial inequality. In October 2020 the London Councils Leaders' Committee agreed a statement2 
committing London Councils to lead and support boroughs on this issue. 
5. The Chief Executives London Committee (CELC) is aligning the contribution of London's senior 
managerial leadership with the London Councils initiative. This is being delivered the CELC Tackling Racial Inequality working group which is chaired by Kim Smith (Chief Executive, London Borough Hammersmith & Fulham) and it engages actively with senior managerial leaders across all London boroughs. The working group seeks to support the work that individual boroughs are undertaking that responds to the needs within their communities and organisations and, where appropriate, develop regional activity. 
6. In addition to the above working group collaborative activity is underway across local government 
service areas to respond to more specific needs such as in health, employment and welfare - this will be explored in more detail when responding to the 4 consultation areas.  
 

## Chief Executives Of London Committee Tackling Racial Inequality Working Group

7. The CELC Tackling Racial Inequality working group was established to develop and lead work to tackle 
racial inequality across London local government, support boroughs in their 'place' leadership role and help build a fairer and more inclusive capital. By outlining the role of the working group this section will describe the strategic and multi-layered pan-London approach that local government has adopted. To help realise its ambition, the working group has developed a programme that builds on effective models of intervention and programmes in boroughs. The group's work programme consists of three key areas which encapsulates the breadth of activity and action needed but also already underway across London local government: 
- 
Demonstrating leadership - ensuring London local government demonstrates visible leadership on 
this agenda within our organisations but also across partnerships, our 'places' and our communities. This includes: 
o 
Establishing public commitments across boroughs to lead and act on this agenda. 
o 
Developing tools and guidance to support borough activity and develop solutions to significant regional challenges. 
o 
Developing an assurance and accountability approach for local government around tackling racial inequality. 
- 
Our role as large employers - as large employers within our communities and across the region, local 
government must be an exemplar for inclusive workforces and we seek to accelerate action to ensure this. Some boroughs have made significant progress to establish inclusive workforces and others are developing work to become more diverse, culturally aware and to support the development of their staff. This activity is centred around supporting boroughs by unblocking existing barriers (e.g. around recruitment) and sharing good practice: 
o 
Developing more robust workforce data across boroughs to improve our understanding of trends within our organisations, consistency around workforce data collection and transparency through data publication. 
o 
Collecting and sharing good practice around initiatives to develop 'BAME' staff and to establish more inclusive workforces and work practices. 
- 
Challenge and improve practice across services - Sharing and building upon examples of good 
practices at borough, sub-regional and regional levels to actively tackle racial inequality. There are many positive examples of how boroughs are actively tackling racial inequality, which will be identified in this paper. However, local government can do more to share these examples to enable learning but 
also understand what could be replicated elsewhere or at different levels (e.g. sub-regional or pan- London). This activity includes: 
o 
Creating a repository of good practice that will be shared across London local government. 
o 
Reviewing London local government service areas, at a regional level, to understand existing practices and drive additional activity. 
8. The working group reflects the level of appetite and ambition in London local government to embed the 
need to tackle racial inequality in the way we operate and in the services we deliver. The working group and the programme more broadly will continue to develop to best establish a local government approach to this agenda and explore how this can also involve or include wider partnerships. 

## Addressing The Causes Of Racial And Ethnic Disparities In The Uk (Question 1) 9. The Causes Of Racial And Ethnic Disparities In The Uk Are Multifaceted And Complex - Inextricably Linked

to history and culture, as reflected in our society, systems and institutions. This response will not 
examine or interrogate these causes as there is a plethora of academic, public sector and personal perspectives that detail this, instead it will focus on solutions, with reference to the activity underway in London local government. 
10. Nevertheless, as public services and system leaders, we do recognise the need to consider and reflect 
on the historical influences that shape contemporary British attitudes to race and ethnicity (e.g. the British colonial past and subsequent perceptions of people from Black, Asian and other minority ethnic backgrounds) - to allow an informed understanding of the origins of existing disparities (e.g. barriers to opportunities). Councils are well placed to continue conversations with our communities, with a view to deepening our collective understanding and subsequently work collaboratively to influence cultural 
change and seek to rectify any troubled historical relationships with 'BAME' communities. Adopting inclusive language, supported by meaningful actions, provides a solid foundation for enabling people of all ethnic backgrounds and cultures to thrive. 
 
11. The adoption of a London local government Tackling Racial Inequality programme and a supporting 
statement committing London Councils as an organisation to deliver a programme of activity, is symbolic of our commitment to lead change and to shape an inclusive way forward. The programme outlined in this response demonstrates the need for more tangible action, both in relation to outcomes and experience, but also in relation to cultural attitudes.  
 
12. For example, in relations to the latter, work is being explored in London local government around the 
use and categorisation of the term 'BAME'. The categorisation of 'BAME' has increasingly come under the spotlight as a term that can serve to homogenise different histories, identities and cultures, including the challenges and inequalities they experience. For local government this can hinder relationships with communities and residents and result in ineffective policy making or service delivery which can leave certain groups behind. Hence, we are exploring an alternative to 'BAME' and seeking to create a culture in local government that aims to understand and tailor initiatives or solutions towards different ethnicities, cultures and communities. 
 
13. London local government recognises the need to understand the challenges and barriers within our own 
sector. Chief Executives recently sponsored a survey that looked across London local government service areas to identify some of the core challenges and barriers within the sector - these included: 
 
- 
Changing existing workforce and organisational attitudes. 
- 
Catering mainstream services to the needs of Black, Asian and minority ethnic communities, reflecting the need to improve cultural competency within organisations. 
- 
Addressing broader societal disparities to tackle inequality and the persistent disproportionate outcomes and impacts on certain ethnic groups. 
- 
Addressing the lack of robust and granular data to better inform policy and decisions. 
14. This framework will help act as a cornerstone to our activity, particularly as we recognise the collective 
need, across boroughs and with other public sectors partners, to ensure the sector is more inclusive and proactively seeks to tackle disproportionality and racial inequality. 
Reflecting on our own learning in relation to the underpinning causes of racial and ethnic disparities and to help inform possible solutions, we propose the Commission focuses on the following key lines of inquiry: 
- 
Culture change and understanding the problems  

o 
Cultural and historical attitudes inform our everyday views and perceptions, and public sector 
agencies have a crucial role in creating inclusivity within our actions and discourse. 
o 
How can public sector agencies establish and embed inclusive cultures that consists of a genuine understanding of the root cause(s) of racial and ethnic disparities but also tailored provision to those impacted communities?  
o 
What is the role of public sector agencies in promoting inclusive messages? 
- 
Language 
o 
How can we best work with communities to understand the impact of the language we use and adopt more inclusive terminology e.g. reviewing the use and categorisation of BAME? 

## Improving Representation, Retention And Progression Opportunities For People Of Different Ethnic Backgrounds In Public Sector Workforces (Question 2) 15. Accelerating Inclusive Workforces Is A Key Component Of The Tackling Racial Inequality Programme. This

means promoting diversity within local government organisations, establishing a culturally competent 
workforce and actively developing staff with a particular focus on those from 'BAME' backgrounds. This section will focus on the pan-London activity that is being driven and developed both around a regional approach and to support borough level activity. 

## Diverse Workforces And Cultural Competency

16. The drive of this focus is the view that, as public sector organisations, we should aim to reflect the 
communities we serve at all levels of the organisation - this will help improve the services we deliver to residents and build trusting and helpful relations with communities. This is especially important in London given our diverse communities, therefore representativeness across organisations will help acknowledge, incorporate or embed the histories and needs of different communities in our services. 
 
17. London local authorities with leading practice have already made significant progress to establish 
inclusive workforces - that is, they have a diverse and culturally competent workforce that reflects the communities they serve (i.e. staff from a range of backgrounds and cultures, including knowledge and experience of local communities). One example is the London Borough of Brent which, in their workforce strategy3, aim to ensure the council has a representative workforce and at least 80% of the same representation exists in their senior management. This has largely been achieved as 65% of staff are from BAME backgrounds compared with 62% of the Brent population4 
 
18. At a pan-London level we aim to replicate and build on existing borough initiatives and good practice. 
This consists of developing pan-London projects to establish consistency and learning across boroughs, particularly around the following themes: 
 
- 
Recruitment - reviewing and sharing recruitment practices. Inclusive recruitment practices are a 
key gateway to establishing diverse and representative local government workforces. Across boroughs there are many examples of how local government is striving to establish inclusive practices, for 
example: 
o 
Diverse recruitment panels, at all stages and levels of recruitment. 
o 
Collecting and reviewing recruitment data to understand the background of applicants e.g. to inform recruitment campaigns. 
o 
Establishing apprenticeship and graduate schemes that focus on attracting and developing talent from local areas and communities. 
- 
There is increasing appetite across local authorities to adopt more inclusive recruitment practices, hence the London programme seeks to facilitate this through a repository and learning hub that hosts promising and good practice and establish a peer support network that enables different boroughs to connect and learn from each other. The principle of a repository and learning hub also applies beyond recruitment practices and initiatives to encompass activity to tackle racial inequality more broadly. 
- 
Data - understanding our workforces. Accessible and robust data is essential to understand the 
composition of our organisations and understand the perspectives of our staff. For instance, across London local government there are different approaches to workforce data collection and levels of maturity in terms of understanding workforce perspectives in relation to race (e.g. representative 
leadership, diversity, opportunities etc). Whilst boroughs should remain autonomous in their data collection processes there is a level of inconsistency across boroughs - mainly in reference in the level of detail some explore to understand the diversity and representativeness across their workforce that indicates an opportunity to establish consistency around the type of data collected, particularly to enable reliable benchmarking, but also to develop a more complete picture of London local government workforces. As part of the London programme, we are reviewing data collection and analysing data to develop a more robust picture across local authorities - this includes: 

o 
Collecting and compiling data across borough on ethnicity and pay band (rather than grade) to better understand the composition of staff by ethnicity based on roles and seniority. 
o 
Conducting an exercise to understand how, across London local government, we can collect more robust workforce data. This also includes how we can better share data, linking into establishing solutions around improving trust and confidence around sharing ethnicity data among 'BAME' staff with organisations. 
o 
Exploring how to improve transparency around workforce data in relation to ethnicity. 

## Developing Bame Staff And Aspiring Senior Leaders

19. To reflect the diversity within the capital it is important to ensure there is visible 'BAME' leadership 
within our organisations, in addition to actively enabling aspiring leaders from any background to thrive. London local government established the London Leadership Programme (LLP) which aims to provide leadership development opportunities, in addition to those opportunities already offered across individual London local authorities and service specific development approaches. It seeks to equip staff with the skills and understanding to take on senior positions across the capital in the next three to five years. The programme has been running since the autumn of 2017 and through a pilot and four cohorts 150 senior managers have been offered the development opportunity. 
20. It has always been an explicit ambition of the LLP to create a more diverse group of future leaders and 
a talent pool that better reflects the city and its communities. However, given the drive and momentum to tackle system racism, coupled with recent events, the LLP is currently being updated to reflect this new context and respond to the opportunity to rebalance, reinvent and recreate. 
21. The LLP Board is now commissioning two more, sequential cohorts (cohorts 5 and 6) of the LLP over 
the next two years, and a fundamental review of the programme's content. The Invitation To Tender 
(ITT) makes explicit the need to reflect throughout the programme content, group work and selection of contributors the need to talk about and tackle social and racial injustices and acknowledge that colleagues from all backgrounds have a role to play in the discussion. This also includes equipping aspiring leaders with the skills to rise to the challenge of leading diverse organisations and places. 
22. This reform of the programme is also in acknowledgement of the fact that the ethnicity of local 
government leaders must better reflect London's diverse communities.  As such, the ITT also asks contractors to provide an additional package/ programme of development activity for 'BAME' participants, allowing them to explore and share the challenges and issues specific to their experiences and leadership journeys. This additional offer will be carefully managed and tailored to individual needs. It could, for example, take the form of 1-2-1 professional coaching and/ or mentoring. 
Reflecting on our own learning **in relation public sector workforces** and to help inform possible solutions, we propose the Commission focuses on the following **key lines of inquiry:** 
- 
Inclusive workforce - diversity and cultural competency are essential within any workforce and there is space for the public sector to lead by example. How can we facilitate and support organisations to adopt inclusive recruitment and development initiatives? 

- 
Data and information - public sector and other agencies can do more to encourage the collection and publication of data that can help us understand where challenges and barriers are within organisation for 'BAME' staff. This can help ensure employers develop targeted programmes, such as the LLP or similar, that can respond to clear gaps within sectors or organisation and ensure employers are accountable for being inclusive. 
- 
Developing 'BAME' staff - there is often a visible challenge around development opportunities for 'BAME' staff and the representativeness at senior levels. There is more that can be done to understand the barriers around development opportunities and leadership positions for BAME staff 
but there is scope to determine how public sector agencies can show leadership around this but also support other organisations to follow suit. 

## Education And Schooling Experience (Questions 3 & 4) 23. Schooling And Education Represent Key Milestones During Any Young Person'S Development And The

impact of a negative schooling experience, lack of education and poor educational outcomes can have significant implications for their life experience. In London there are clear disproportionate outcomes for 
certain ethnic groups, particularly for young Black children and often specifically young Black boys. For example, young Black boys are more likely to achieve lower grades and experience fixed or permanent exclusion. The issue of school exclusions is particularly prominent for Black Caribbean boys as they remain consistently over-represented both national and in London (second only two Roma, Gypsy, Travellers)5, even during the pandemic boroughs have been reporting increases in school exclusions for this cohort. The impact of school exclusions is significant as evidenced in criminal justice data as 89% of children in Young Offender Institutions (2018) had been excluded6 7. The cause of this disproportionality is explored extensively in academic studies (referencing historical, society and school factors; material deprivation, teacher perceptions, discrimination), hence this section will focus on examples in London to tackle the disproportionate outcomes and experiences.  
 
24. Local authorities and schools have an essential role in addressing disproportionality within education 
and ensuring young people have the learning and skills to provide them with more positive life opportunities. Local authorities, working with schools and other partners, have established and are developing innovative practices and initiatives to improve the schooling experience and attainment of disadvantaged young people. Across London there are examples of tailored initiatives in schools that are aimed at raising aspirations and improving education outcomes for young Black children. 

## Lambeth: Raising The Game8.

25. This is a two-year project aimed at tackling the 7-10% academic attainment gap and high exclusion 
rates that Black pupils of Caribbean heritage experience in the borough. The project is based in selected schools across Lambeth working to improve outcomes at all key stages, to raise aspirations and to reduce exclusions for Black pupils of Caribbean heritage who underachieve in relation to their peers nationally and locally. The project consists of 3 strands: 1. Aim High - which intends to expose Black students of all ages to successful Black role models from 
different sectors and life experiences. 
2. Diversifying the curriculum - a teacher lead initiative, within both primary and secondary schools, 
that develops tools for teachers, by teachers centred around actively incorporating Caribbean literature into pupil learning; showcasing diversity in different occupations - promoting the mantra of 'the sky is the limit' for Black pupils - and working across primary and secondary schools to support pupils transition. 
3. Parental Engagement Network - a repository of tools and resources for parents, that will help them 
support their child(ren)'s learning.  
26. The project has resulted in an 11% improvement for Black students at age related expectations at KS2 
in comparison to their peers and 3% improvement at KS4, and an overall reduction in permanent exclusions by 49% and over 70% reduction for Black students of Caribbean heritage. 
27. Haringey has the largest gap in Britain at GCSE between higher achieving White British students and 
lower achieving 'BAME' groups, especially those Black students of Caribbean heritage. In response, HEP have established a programme to address and improve 'BAME' achievement in the borough which 
is outlined in the BAME Achievement Strategy: Raising Black Caribbean and BAME Achievement: 
- 
Achieve outcomes for all children and young people as good as, or better than, anywhere else in the country. 
- 
Close the gaps in attainment for our different ethnic groups and disadvantaged pupils. 
- 
Tackle related inequalities and negative outcomes such as exclusions, which impact on life chances. 28. To deliver the strategy HEP have established and created several resources for schools, public sector 
organisations, pupils and parents: - 
Self-evaluation tools (for schools). 
- 
Vulnerable to Underachievement Checklist which aims to: 
o to promote/target pupils for participation in extra-curricular activities or the need to maintain 
extra-curricular attendance records 
o to be proactive in rewarding pupils/ a group of pupils to build self-esteem, e.g. there could be 
a pattern by gender, ethnicity or ability  
o to reconfigure a tutor group where there are greater pastoral needs or for more staff training 
on attachment theory and how to respond. 
o to help governors in directing resources at greatest need or secure class-wide support from 
Early Help 
- 
'BAME' action plan template (for schools). 
- 
'BAME' children literature (for parents and pupils). 
- 
Achievement database to capture key trends around education in the borough. 29. These are just two examples of important activity to improve the achievement and schooling 
experiences of young Black people - there are many other programmes and projects across boroughs that are actively addressing this challenge and making a real difference in outcomes. For example: - 
Brent have an ongoing programme aimed at raising the achievement of young Black men - this has resulted in an improvement in exclusion rates for Black students of Caribbean heritage, including a 
9.4% reduction in permanent exclusion in the last year.10 
- 
Lewisham are conducting tailored activity to improve outcomes for 'BAME' pupils, with significant 
focus on addressing disproportionate schooling outcomes for Black pupils of Caribbean heritage.11 
- 
Hackney have established a programme of work to improve outcomes for young black men, this includes, but is not limited to, addressing educational outcomes for young Black men of Caribbean heritage.12 
30. Targeted interventions and tailored initiatives are an essential component of tackling the 
disproportionate outcomes in education, however to establish genuine change there needs to be a more inclusive system that enables children of all backgrounds the thrive. The examples and the general principles described above are key elements of change that are required in the education system. They also reflect ideas that can be built upon or replicated across different areas. 
Reflecting on our own learning **in relation to education and schooling** and to help inform possible 
solutions, we propose the Commission focuses on the following **key lines of inquiry:** - 
Targeted initiatives to raise the aspiration of 'BAME' children - to achieve a fundamental difference in education for 'BAME' children there needs to be a combination of system wide change and 
targeted intervention. The examples in this section allude to the challenges within the education system (e.g. attainment gaps, extra-curricular activity; the curriculum) and describes the different possible solutions, but there is also merit in learning from and replicating these solutions at a larger scale. Additionally, it is important to have an increase focused on 'BAME' role models - that is, showcasing young people or adults from various 'BAME' backgrounds that have demonstrated or achieved success to influence young people's ambitions. This will help permeate a culture within education institutions that strives to target and support those ethnic groups that can be left behind. 
- 
The role of education in supporting cultural change - the point is twofold. Within education there has been progress to ensure schools and institutions are inclusive but there is still more progress 
required to sharpen practices and attitudes. This includes improving racial literacy and cultural competency among teachers and school leaders, and ensuring that key agencies recognise the role of people and institutions in potentially holding attainment back. Promoting inclusive institutions has a much broader and important role in helping to establish cultural change by educating future generations and supporting them within an inclusive, diverse environment. This diverse environment can be reinforced through reviewing the representation of school leaders and governors (linking with the ambitions outlined in response to question 2 above). It is important to determine the role schools and similar institutions can play within this context. 

## Employment & Opportunity (Question 5) 31. London Local Government Regional Activity Around Employment And Opportunity Is Being Driven Through

two programmes - the CELC Economy and Employment working group and the London Recovery 
Programme13. The former works on local government specific initiatives and the latter, which is Co- Chaired by the London Mayor and Chair of London Councils (Cllr Georgia Gould), is also developing cross-sector initiatives to drive longer term employment and opportunity as the capital recovers from the pandemic. Within these programmes one of the key areas of activity is addressing the challenges and disproportionality around equal opportunities and employment for different ethnic groups. This section will describe the challenges in London around employment and opportunity and solutions being explored by local government. 32. Contextually, before the pandemic, there were clear disparities for 'BAME' Londoners in relation to 
employment and opportunities. Now, in a similar way to the other areas explored in this consultation, as 
a result of the pandemic, we can see there has been a disproportionate impact on 'BAME' communities which has exacerbated pre-existing inequalities: 
 
- 
Pre-pandemic o Employment rate: before the pandemic the employment rate for 'BAME' Londoners (67.1) was 
significantly lower than that of White Londoners (79.3) in 2019.14  
o Pay gap: Data on hourly pay (2010 - 2019) also shows that 'BAME' Londoners (£13.50) are 
paid substantially less per hour than Londoners on average (£15.70). In comparison, White Londoners were paid £16.74 on average an hour for the same period15. In fact, the ethnicity pay gap differs across regions and is largest in London at 23.8%. 
- 
Impact of the pandemic 
o Employment levels16: between April and June 2020, the number of Black Londoners in work has 
declined by 9.5% on the quarter and 11.7% on the year. In comparison, the number of all Londoners in work decreased by 1.5%, the number of mixed Londoners in work decreased by 5.7% and the number of White Londoners in work decreased by 0.4%. 
o Employment rate17: although Black Londoners experienced the largest fall in employment levels, 
those from a mixed background saw the greatest quarterly fall in employment rate - 5.2%, compared to 0.7% for London as a whole. London employment rates in Q2 2020 remain uneven: London average (76.4%), White (79.8%), Asian (72.3%), Black (66.7%), Mixed (68.2%) and Other (72.4%). 
o Projections for the future18: the London Assembly estimates that 1.1 million jobs are at risk in 
London. Over a third (38%) of those at greatest risk are from 'BAME' backgrounds. Looking at the UK as a whole, 15% of workers in sector which have shut down because of the coronavirus are from a 'BAME' background, compared to 12% of all workers.19 
33. In London a range of barriers and challenges have been identified around the disparities for 'BAME' 
Londoners' - understanding and tackling these are essential to establish meaningful solutions. In summary those barriers include: - 
'BAME' employees working in London are more likely than those working in England to agree that 
their identity or background can have an effect on opportunities20.  
- 
Education and training are a key barrier for Black students and those from low income backgrounds having the highest drop-out rates from higher education21. Higher education is often an important enabler to social mobility, however access to aspiring 'BAME' students can often be limited particularly to the top universities - for example studies have found that Russell group universities are less likely to offer places to pupils from 'BAME' backgrounds even when they have the same grades as white peers22 
- 
According to the Mayor's equality, diversity and inclusion strategy some of the key factors contributing to lower employment rates among these groups include language barriers, family structures, cultural differences and others. However, it also raises concerns about race 
discrimination in the job market23.  
- 
According to research by Community links, the key employment barriers 'BAME' women in East 
London face include lack of confidence, lack of (financial) independence among women, as well as social and cultural barriers (e.g. not having family support to work), as well as not having the required skills and qualifications and lack of familiarity with recruitment processes24.  
- 
According to the London Borough of Camden, the coronavirus crisis is presenting an additional 
barrier to 'BAME' workers as many of them work in retail, hospitality and construction. Therefore, 
they are facing additional sector-specific challenges as lockdown and social distancing measures are preventing the businesses in which they work to operate effectively25.  
- 
Even those aspiring and thriving entrepreneurs from the 'BAME' backgrounds experience disproportionality - these will be covered in the British Business Bank report and submission to this consultation but some of the facts include lower business success and lower turnover for certain ethnic groups26. 
34. The above demonstrates that engagement with different communities and ethnic groups must be at the 
heart of solutions. There is robust data available that provides concrete facts which indicates clear structural and institutional issues (e.g. employment and pay gaps). However, to develop solutions there 
is must be a complementary approach to address common, broad challenges (e.g. education and training) and those that require some tailored responses based on the experiences of individual communities or groups. In London activity is being developed to ensure there is a robust response to exacerbated disparities around employment and opportunity for 'BAME' Londoners. Across London local government boroughs have developed targeted initiatives to support 'BAME' communities to help them develop skills to enter or re-enter employment. Furthermore, within the London Recovery Programme, an action plan is being developed that will specifically address structural inequalities in the labour market, including those experienced by 'BAME' communities and this will be reflected in the membership of the steering/expert group overseeing the development of the action plan. 
Reflecting on our own learning **in relation to employment and opportunities** and to help inform possible solutions, we propose the Commission focuses on the following **key lines of inquiry:** 
- 
Addressing barriers and developing solutions with affected communities. There are clear structural 
and institutional barriers that prevent 'BAME' people from thriving and their voice is essential to inform solutions. How can we best ensure those voices activity inform solutions are all levels? A group designed to explore this, consisting of representation from 'BAME' businesses and public sector leaders may be an effective means to ensure this.  
- 
Working with employers - the role of employers is often overlooked, however it is essential that they are included within solutions to both understand their perspective and to encourage them and incorporate them on the journey to become more inclusive. Some studies find that more diverse business, including ethnic diversity, are often higher performing which reinforces the business case for inclusivity. In London there is a challenge around diversity and inclusivity within growth sectors in the economy e.g. the creative and cultural industries and green economy, hence it is important to 
actively engage and focus and specific sectors. 
- 
Equal access to skills development - how can public sector agencies and businesses enable access to skills that can support people, from all ethnic backgrounds, into good and rewarding work? 

## Health Inequalities (Questions 6 & 7) 35. London'S Population Is Diverse And Complex, With A Growing Population That Is Predicted To Increase By 3

million people by 2050, reaching a potential 10.5 million by 204127. In relation to ethnic diversity, 40% of 
Londoners identify themselves as 'BAME', compared to 45% from the white British community, furthermore 26 boroughs are within the most diverse areas in the country. This ethnic diversity is also accompanied by different health needs and inequalities - for example 'BAME' communities are more likely to suffer from infectious diseases, including HIV, tuberculosis, Hepatitis B and C which are compounded by related issues such as deprivation. Additionally, there are also challenges around mental health which also affect overall health outcomes. This section will outline the health inequalities in London including the drivers of these, with a focus on the impact of the pandemic, and describe the activity in London local government to tackle this. 

## The Impact Of Covid On Bame Londoners 36. The Public Health England Review 'Beyond The Data: Understanding The Impact Of Covid-19 On Bame

groups' (June, 2020) provided the first indication about the disproportionate impact on certain groups, including analysis where people lived and how their occupation made these groups more vulnerable to Covid. The research also included extensive engagement with 4,000 stakeholders from a range of communities across London. The findings suggested that Covid exacerbated and exposed the already deep-seated health inequalities in London, and that the impact of the pandemic did not affect all groups equally. The key findings revealed the following: - 
The highest age standardised diagnosis rates of Covid-19 per 100,000 population were in Black ethnic groups, 486 in females and 649 in males. Compared to the White population reporting 220 in females and 224 in males. 
- 
'BAME' groups were more likely to be tested and to test positive. 
- 
'BAME' have an increased risk of death associated with Covid. 
- 
Ethnicity and income inequality are interdependently associated with Covid-19 mortality. 
- 
Mortality rates were higher for residents living in more deprives areas of London. 
  
37. A later PHE report 'Disparities in the Risk and Outcomes of Covid-19' provided an analysis based on 
PHE surveillance data, providing a better understanding of the impact of the pandemic on 'BAME' communities. The areas identified in terms of the impact of the Covid include: - 
Age is the greatest factor of people diagnosed with Covid, people over the age or 80 were most at risk, were 70 times more likely to die than those aged under 40 years old. 
- 
The risk of Covid cases was higher in those in 'BAME' groups. Among those tested positive for Covid, people from the Bangladeshi ethnicity had twice the risk of death compared to the White British community. 
- 
People of Chinese, Indian, Pakistani, other Asian, Caribbean and other Black ethnicity and had between 10% and 50% higher risk of death compared to the White British community.   
- 
Critical care admissions were 28% more likely in South Asian and 36% more likely in Black ethnic groups, compared to white counterparts (considering age, sex and location). 38. The impact of Covid on 'BAME' communities, must also consider the external factors impacting on the 
disproportionality. There is also a propensity for economic disadvantage to be associated with 
 
 
unhealthy behaviours such as smoking, obesity, diabetes and hypertension, making Covid symptoms 
more severe and fatal. Those with pre-existing health conditions, such a diabetes and obesity, which 
are more prevalent in 'BAME' communities, increased the risk of having severe infection, this is exacerbated when examining living in deprived areas, where there is a higher percentage of people living with chronic diseases and long term conditions.    
 
39. Economic factors, such as unemployment and poverty also influence mental health outcomes, who are 
disadvantaged economically, especially those from the migrant, refugee population and those with no recourse to public funds. Much of the focus to improve the mental health of Londoners, is carried forward by the pan-London ThriveLDN28 initiative, which is a London supported programme aimed to protect and improve mental health, recent work is also looking at the impact of Covid on the mental health of Londoners. 
40. The 'BAME' population are more likely to work in front line positions within the NHS and care sector, 
with less access to PPE equipment. Care workers nursing auxiliaries, security guards and transport workers, and those working outside of the home, giving rise to a greater exposure of Covid. 'BAME' 
groups are more likely to use the public transport system to travel to and from work. Equally, people living in poor and high density housing are more at risk, including those living in intergenerational households, along with poor quality and overcrowded housing.  
 
41. A great concern was the response from stakeholders who expressed fear and dismay about the 
knowledge that their 'BAME' communities were disproportionately impacted. More critically, it revealed that these communities suffered stigma and discrimination, especially among key workers working, working to support those in ill health. The report also revealed that fewer people from ethnic communities are less likely to seek medical help, from fear of being diagnosed with Covid, and present late to medical services, fuelling the lack of trust in medical services and heath care.  

## London Local Government Activity

42. London's local government are required to have due regard to reduce health inequalities within their 
communities. All boroughs are required to produce a local Health Inequalities which sets out the actions each authority wishes to take to reduce the gap within 'BAME' communities. Complementing this work, is the role the Health and Wellbeing Boards, who have a leadership role to promote health equalities as a key element of their work. 
43. Following the findings of the initial PHE report, the London Health Board, which is Chaired by the Mayor 
of London, and represents a range of health partners agreed to set up a Health Equity Group (HEG). The HEG, Chaired by Kevin Fenton (Regional Director for London, PHE) and Will Tuckley (Chief Executive, LB Tower Hamlets), is tasked with addressing immediate issues facing communities, supporting learning from the Covid Response and reducing the impact 'BAME' groups and those with other protected characteristics. 
44. At a borough level Integrated Care Systems (ICSs), are working together across London to address 
health inequalities to build on what they know about their communities, in order to be more responsive to their local population. This includes focusing on population health and gathering data to implement local responses to reducing health inequalities. Activities already being supported include mobilising communities and faith leaders to work with vulnerable communities, and supporting prevention activity, focussing on prevention programmes that can be replicated across London, considering how place and the environment has an impact. This includes looking at how houses in multiple occupation and multigenerational and anchor institutions can support this agenda and making best use of digital intelligence and behavioural insights. 
45. London Councils is also supporting the work of the London Vision29  which has a goal to make London 
the healthiest global city and tackle persistent and structural inequalities of outcome. Through this health partners have committed to reduce the significant and persistent resistant inequalities, promote good health and tackle the causes of poor health. There is commitment to reflect on the experiences of 
Covid and provide city wide responsive action. 
Reflecting on our own learning **around health inequalities** and to help inform possible solutions, we propose the Commission focuses on the following **key lines of inquiry:** - 
Making better use of data - across the system there is an opportunity for public agencies to determine how to better use data to understand the challenges, outcomes and experiences for different ethnic groups i.e. by incorporating learning from the pandemic response and outcomes, how data can be used to improve health outcomes? Across London's health partnerships we are exploring a range of activity, including how to improve mandatory ethnic data collection at death certification; support community participatory research; accelerate the development of culturally 
competent occupational risk assessment tools; fund and develop culturally competent COVID-19 campaigns and programmes; and ensure that COVID-19 recovery strategies actively reduce inequalities caused by the wider determinants of health to create long term sustainable change. - 
Locally led responses - communities understand local needs and, as evidenced in the initial lockdown, there is appetite for people to provide active help and support within their local communities. It is essential to ensure communities are embedded within solutions to ethnic and community health inequalities and there is a role for the public sector, with community leaders, to facilitate this. Working in partnership, at local ICS level where there is work being undertaken to support and re-engage with local communities and to co-produce responses tailored to their special needs.  
 

- 
Public health resourcing - the public health grant, which funds local authorities to carry out public health duties, has fallen substantially since 2015. Currently (2020/21) London receives around £649 million funding allocation, £69.64 per head of population - in 2015/16 funding amounted to £698 million, £80.75 per head. In real terms, funding has fallen by £55.8 million since 2015, the equivalent of -13% fall per Londoner. Public health services are at the heart of the pandemic response and the reduction in funding continues to limit to amount of support boroughs, with partners can provide to 
vulnerable people. The case needs to be made for a substantial increase in public health funding for 2021/2022, across the country, to ensure that the public sectors commitment to public health prevention and activities is sustainable in the longer term. 

## Crime & Policing (Question 8 & 9) 46. Disproportionality In The Criminal Justice System (Cjs) And Associated Challenges Around Trust And

confidence have been an area of persistent concern both within the London and national contexts. In 
London the core concern is the link between racial inequality and disproportionate outcomes within the CJS. Black communities, and particularly young Black men, are over-represented and are more likely to experience disproportionate outcomes in the CJS, including the Youth Justice System (YJS). However, the disproportionate outcomes we see in the CJS are, to a significant extent, the product of underlying inequalities that can best be solved by tackling the wider systemic, societal and institutional challenges. This section will highlight the issues in London and identify some of the activity in local government to tackle this. 
47. 'BAME' Londoners, particularly those from Black communities, are more likely to experience a range of 
negative outcomes when encountering the CJS. These issues are exacerbated when examining the YJS which is characterised by over-representation of 'BAME' - particularly Black - children and young 
people who also have different experiences (whether it be decisions or outcomes) throughout most processes in the system. For example: 
- 
Black children are more likely to be arrested than White or Asian children. 
- 
White children are more likely to get a caution than Black children. 
- 
Black children occupy higher representation in more serious offence groups. 
- 
BAME children are more likely to be sentenced to custody. 
- 
Black children have experienced the lowest rate of decrease in first time entrants. 48. When interrogating this further, young Black men experience disparity arguably at every stage of the 
CJS - from policing, through the court system, to prisons and probation. For example, young Black men disproportionately: 
- 
Experience a lack of trust and associated animosity with law enforcement. 
- 
Experience the hard end of police enforcement (stop and search; tasers; traffic stops). 
- 
Experience formal sanctions rather than formal/ informal warnings and out of court disposals, reaching all the way to imprisonment (the court system amplifies disproportionality from the earlier stages of the journey of young Black men). 
49. Furthermore, linked to outcomes within the system, the latest national report on youth offending 
services inspections30 makes emerging findings around the quality of provision for different ethnic groups; whereby, of the inspected out of court cases those involving Asian young people received far better quality of provision than any other ethnic group. Additionally, in London, people of an Asian background have experienced the largest decrease of any ethnic group in custody (-28.8% compared to an average -12%) and the largest decrease in remands for Asian young people31. 
50. There are many partners across the system that are working to tackle this disproportionality, including a 
range of service areas in local government that are a contributing to this agenda. This response will draw upon the example that aim to tackle and reduce disproportionality with youth offending, which then has crucial and subsequent impact on young people's lives and possible paths towards criminality. Within these examples, it is important to recognise that visible action is essential to help build trust between communities and criminal justice agencies. 

## Youth Offending Teams (Yots)

 
51. YOTs have an instrumental role in tackling and preventing criminality among young people, this 
includes active work to support those groups that are more likely to encounter the YJS and experience 
subsequent disproportionate outcomes. Many YOTs have been providing tailored and appropriate services and support to these groups. The following are examples of the work and activity being undertaken across boroughs, by YOTs to tackle disproportionality: 
 
- 
Diverting young people away from the courts - Out of Court Disposals (OOCD). OOCDs are an effective way of providing a victim focused and constructive solution to an offence which can also divert or 'triage' young people away from the CJS. However, this option is currently under-utilised by young Black people - hence we see this group over-represented for first-time offending, reoffending and in youth prisons. The causes of this link to a lack trust and confidence in the CJS (i.e. increased likelihood 
of 'no comment' interviews) and a lack understanding about the options available to them having 
committed an offence. To tackle this, boroughs have taken steps to actively promote and raise awareness of the alternative options available to those young people who have committed an offence and, by working with partners, seek to increase the use of this option having recognised this as an 
important contributor to reducing the disproportionate number of young Black people experiencing court outcomes. At the heart of this approach is building relationships with young people and their communities - being transparent around the options available to them and actively diverting them away from the courts contributes significantly towards developing trust. 
- 
YOTs also contribute to broader activity being driven by the YJB, for example through the disproportionality toolkit and their submissions to the YJB on national standards. The toolkit enables teams to identify where in the system disproportionality occurs and through submissions to the YJB YOTs outline a cross-sector action plan (involving all key stakeholders) to tackle disproportionality. Through this there are examples of local collaborations to deliver change such as Haringey and Islington YOTs are working with City University in relation to serious youth violence and disproportionality32 33. 

## Children'S Services

52. London local governments Children's Services have a core role in supporting young people and 
ensuring they can thrive throughout life. Across London, boroughs have been undertaking proactive work to improve outcomes for young people from different ethnic backgrounds - this includes an active role in tackling racial inequality. In addition to work of individual borough services, the London 
Innovation and Improvement Alliance34 have a dedicated disproportionality and anti-racism workstream which attempts to collate good practice across London. Examples of positive action includes: - 
Establishing Youth Justice disproportionality sub-regional working groups, led by Directors of 
Children's Services, dedicated to reducing racial disparities for 'BAME' young people, particularly 
those from Black communities. The first of these groups have been established in North Central London with other sub-regions expected to follow and develop their own networks. 
- 
Directors of Children's Services have been working with the YJB on a proposed alternative to custody provision in the London Accommodation Pathfinder project. Children from London are overrepresented in the secure estate and 80% of those receiving a remand or custodial sentence are 
from 'BAME' backgrounds. The proposed provision will comprise four houses across London 
providing for twenty places which will be a direct alternative to custody. The Pathfinder will test 
approaches which, if successful, will directly address the disproportionate use of custody for 'BAME' 
and particularly young Black men in London. 

## The Broader Programme Of Activity

53. The activity of YOTs and Children's Services is part of a broader programme within London local 
government and across other criminal justice agencies to tackle disproportionality in the CJS. This programme consists of a breadth of action that recognising a range of barriers that must be unlocked across the system if we are develop meaningful and effective solution. The following high-level actions have been committed to by London local government: - 
Working with partners to build on local activity to establish a strategic pan-London approach around serious youth violence and child criminal exploitation. This is in recognition of clear synergies around the cohort of children that two areas often work with and the negative impact and experience these children experience. 
 
- 
Developing the work of London boroughs to support and advocate for young people, in particular to keep them out of the CJS. For example, reviewing existing contracts for appropriate adult services provision and understanding existing activity and levels of consistency across London. 
- 
Improving data by developing existing data repositories (e.g. London Innovation and Improvement Alliance data) to establish a pan-London pitch around critical milestones, with the view of identifying when and what interventions are required. This entails improving data sharing and accessibility in relation to understanding and tackling disproportionality in the CJS, including challenges during the key life milestones of a child or young person's development, and then developing a data dashboard that maps the outcomes and experiences in London for different ethnic groups (i.e. broken down by ethnicity) during key development milestones (e.g. education, mental health, deprivation) and within the CJS (e.g. pre-court; court; secure estate). 
- 
Sharing best practice - the good practice shared in this section exemplifies the positive activity underway and the need for partners to do more to promote, learn from and share experiences and outcomes e.g. proactive activity in schools to tackle disproportionate outcomes and sub-regional 
activity dedicated to tackle racial inequality. There is also merit in prioritising the identification and dissemination of good practice to help establish an immediate impact on practitioners' day-to-day work. 
Reflecting on our own learning **in disproportionality in the Criminal Justice System** and to help inform possible solutions, we propose the Commission focuses on the following **key lines of inquiry:** 

 
- 
How to understand and tackle the 'upstream' drivers of disproportionality in the CJS: 
o This would allow a strategic response to disproportionality within the CJS, whilst recognising 
that the challenges around trust and confidence impacts everyone within the effected communities and ethnic groups. There must be responses for all cohorts within these groups.  
o A focus on developing solutions for young people is essential, not only because of presenting 
vulnerabilities, but also as a platform for generational change. 
o Evidence suggests that criminality for young people is significantly linked with other 
developmental milestones (education, deprivation etc). Our evidence suggests that locallyled responses that support young people in a joined-up way (learning, for example from the Troubled Families programme) are most effective in turning young people's lives around, and critically, away from criminality 
o This suggests that the Commission should explore how to support and resource the 
development of locally led offer that understands existing barriers and challenges and ensures young 'BAME' people have equal opportunities and are able to thrive. This, in turn, will help to deter young people from criminality. 
- 
Once in the system, outcomes and experiences for people of Asian backgrounds appears to be improving at a greater rate compared to other ethnic groups. What can we learn from around this? 
- 
How to build on and embed promising practice on diverting young people away from the courts - including use of Out of Court Disposals? 
- 
How to work with young offenders to develop career opportunities away from criminality? 
- 
How to inspire our young people to thrive through the promotion and resourcing of local youth offers that engage creatively with our communities and use inspiring role models to help unlock new, constructive and meaningful opportunities- ranging from sport, volunteering and civic engagement? 

## Conclusion

54. The UK currently has an important window of opportunity to establish genuine change that can tackle, 
reduce and even eradicate persistent ethnic disparities and inequality. Momentum and drive have been developed within our communities, institutions and systems and we must build on this. 
55. London local government strives to be at the forefront of driving improvements for our communities and 
we will continue to develop our programme to ensure the need to tackle racial inequality is embedded in the way we operate as organisations and in the services we deliver. 
56. We look forward to seeing the findings and outcomes of the Commission's call for evidence and would 
welcome the opportunity to be a key partner, working with the commission and wider Government on this important agenda; to pilot any initiative; and to deliver tangible improvements.