Diversity Unit

Equality Policy

January 2022

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Contents
Contents....................................................................................................................................... 2
British Council Equality Policy ...................................................................................................... 3
Introduction............................................................................................................................... 3
Equality at the British Council ............................................................................................... 3
Valuing diversity to support inclusion .................................................................................... 3
General statements .................................................................................................................. 4
Legislation ................................................................................................................................ 5
Unjustified discrimination ...................................................................................................... 5
Discrimination – motives and stereotypes............................................................................. 5
Positive discrimination and positive action ............................................................................ 6
Recruitment and selection ........................................................................................................ 7
Performance management ....................................................................................................... 7
Primary grounds ....................................................................................................................... 8
Age ....................................................................................................................................... 8
Disability ............................................................................................................................... 8
HIV and AIDS........................................................................................................................ 9
Gender .................................................................................................................................. 9Race / Ethnicity and Culture ............................................................................................... 10
Religion and Belief .............................................................................................................. 11
Sexual Orientation .............................................................................................................. 11
Socio-economic background............................................................................................... 12
Equality and pay ..................................................................................................................... 12
Bullying and harassment ........................................................................................................ 13
Grievances and/or Concerns .................................................................................................. 13
Speaking Up ........................................................................................................................... 14
Responsibilities....................................................................................................................... 14
Monitoring, evaluation and legal compliance .......................................................................... 15
Communication....................................................................................................................... 16
Review.................................................................................................................................... 16

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British Council Equality Policy
Introduction
Equality, diversity and inclusion (EDI) support the range and breadth of cultural relations
work that we undertake across our global network of offices. They are essential to enable
deep, trusting, mutually beneficial relationships. EDI enhances our brand, reputation andour impact on people and on our planet.
Our organisational mission and vision, and our values - open and committed, inclusive
and expert, optimistic and bold - inform our Equality Policy. Alongside our Code of
Conduct and other relevant policies and guiding principles (such as the global principles
on transforming the way we work), the Equality Policy helps determine how we behave toall those we have contact with. It supports compliance and managing risk.
Our Equality, Diversity and Inclusion (EDI) Strategy sets out our vision and a framework for
implementing our Equality Policy. It specifies objectives and tools that help to give meaning to
the principles and commitments laid down in our Equality Policy.
The Equality Policy has the full support of the British Council Board of Trustees, theChief Executive Officer and Senior Leadership Team who are ultimately accountablefor its delivery. All staff irrespective of their work base are required to ensure their
behaviour conforms with it.

Equality at the British Council
Equality seeks to eradicate unjustified discrimination on irrelevant grounds and promote
human rights and social justice.
When we talk about equality at the British Council, we mean treating people fairly,
impartially and without bias. We mean creating conditions in the workplace and wider
society which encourage and value diversity, promote dignity and inclusion and a culturally
sensitive approach.
Equality doesn’t mean treating everyone the same. Rather it means treating people
equitably. This involves acknowledging and trying to redress imbalances through adifferentiated approach, where necessary and appropriate.
Our Equality Policy originates from the United Kingdom (UK) because we are anorganisation with roots and headquarters in the UK. However, it applies globally,
wherever local conditions allow. Where practices and legislation are more developedand extensive, we aim to meet these.

Valuing diversity to support inclusion
Our Equality Policy is implemented through our EDI Strategy. Diversity is concerned withwww.britishcouncil.org

3creating an environment supported by practices which benefit the organisation and all those
who work in and with it.
It takes account of the fact that people, whilst similar in many ways, are also different. Such
differences include gender, age, race / ethnicity, sexual orientation, disability, religion and belief,
education, economic status, personality, communication style and approaches to how people
think and work, amongst other things. These differences can significantly impact access toequality.
Understanding, valuing and effectively managing diversity can result in greater participation with
benefits at an individual, team, organisational and wider societal level. This significantly
contributes to the aspiration of inclusion.
Inclusion at the British Council is an active process that aims to create conditions for all people
to fully contribute to our work. It is about making people feel welcome and accepted, especiallythose that are socially excluded, marginalised or under-represented. It is about encouraging
participation so that everyone feels valued, respected and involved thereby fostering a sense of
belonging. It strengthens cultural relations and supports trust between people in different
countries and across the organisation.

General statements
We are committed to ensuring that we have effective policies, strategies, procedures, andprocesses and that we encourage behaviour which promotes equality, encourages diversity
and contributes to an inclusive organisational culture. This includes an Anti-Racism Action
Plan supported by a global Anti-Racism Task Force and Challenge Group.
Many of the policies and their supporting structures cover our external facing work and requirethat we treat our clients, customers and suppliers fairly, with dignity and respect, to earn andmaintain their trust and confidence.
We want to ensure there is no unjustified discrimination on the grounds of age, disability
including HIV/AIDS status, gender including transgender and intersex, marital status
including civil partnership, political opinion, race / ethnicity, religion and belief, sexual
orientation, socio-economic background, spent convictions, trade union activity or
membership, having or not having dependents, work pattern, or on any other irrelevant
grounds.
In addition, we want to ensure we develop our awareness of the differing ways in which
discrimination can be compounded when different characteristics (such as ethnicity andgender, or disability and age) intersect.
We promote equality, good relations and inclusion aligned to the Equality Act 2010, Section
75 of the Northern Ireland Act 1998, the Welsh Language Act 1993, and relevant legislationaligned to the geographical regions in which we operate.
As part of this approach, we undertake equality screening and impact assessments ofpolicies and functions which impact on employees and/or external contacts or the wider

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4community which have high relevance to equality. These impact assessments are a meansof promoting equality and good relations, supporting inclusion, and avoiding unjustified
discrimination, whilst also ensuring that we carefully consider the different needs ofparticular groups. They also contribute to the social value we seek to deliver by raisingawareness and understanding and specifying standards for the work we do which promotes
equality.
We aim to make adjustments to our working arrangements, policies and practices thatenable disabled people to take up employment and progress in their careers, provide
services and consultancy, meaningfully participate in our projects, programmes, classes,
and the examinations we administer, and engage in and help shape other activities.

Legislation
Equality, diversity and inclusion are part of a human rights framework. Many countries inwhich we operate subscribe to the United Nations Declaration on Human Rights, orregional versions of it.
This Convention refers, in Article 14, specifically to the prohibition of discrimination on
grounds such as gender, race, colour, language, religion, political or other opinion, nationalor social origin, association with a national minority, property, birth or other status.
The Human Rights Act 1998 incorporates the European Convention on Human Rights
1952 into UK domestic law.
In many countries in which we operate, aspects of equality are enshrined in law. We strive tomeet both the obligations they set out and the spirit of them.
The key law which informs our policy is Great Britain’s Equality Act 2010. This Act
harmonised and brought together many previous pieces of equality legislation. It has
widened the scope of UK discrimination law beyond the area of employment into theprovision of education and training, in the broadest sense, and the wider supply of goods
and/or services.

Unjustified discrimination
Unjustified discrimination, whether direct or indirect, is a barrier to equality, diversity,
inclusion and human rights. Unjustified discrimination is where decisions are made(whether consciously or not) that favour certain groups or individuals and therefore
disadvantage others, because of particular characteristics they have no control over.
Unjustified discrimination is unacceptable in the British Council on all the grounds
identified within this policy.

Discrimination – motives and stereotypes
Discrimination does not necessarily occur because of a conscious decision. There arewww.britishcouncil.org

5subtle and unconscious ways of unjustifiably discriminating.
Some examples include:•

Making general assumptions about a person’s capabilities, characteristics andinterests•

applying requirements, conditions or criteria without considering whether they
advantage or disadvantage particular groups•

perpetuating micro inequities1•

ignoring intersecting aspects of inequality2.

We therefore need to address all of these.
Stereotypes, which are negative assumptions applied to whole groups of people, have realpotential to lead to unjustified discrimination and so should be very carefully examined andif necessary, challenged. Stereotypical and potentially offensive language and terminology
should be avoided and challenged if identified.

Positive discrimination and positive action
Whilst positive discrimination (which means favourable treatment based on an equality
characteristic) remains generally unlawful within the UK, if local legislation requires, we
may positively discriminate. For example, we may be required to comply with a quota
system under which a fixed percentage of nationals, or disabled people, should be
employed in a particular country.
In many countries, legislation does provide for positive action measures. Positive action
aims to promote equality by improving outcomes for groups who are under-represented or
disadvantaged. For example, by specific encouragement to certain groups to take up
employment opportunities, or by providing training and development for groups that havetraditionally been under-represented.
We sometimes take these measures into account when arranging training courses andother opportunities, and in encouraging applications for jobs where there is underrepresentation in a particular aspect of our workforce.
Positive action sometimes underpins the equality targets we have set to address underrepresentation in our workforce.

1

Micro inequities, micro-aggressions or micro-behaviours are small, subtle differences in treatment that
communicate over time that someone has less value. For more information see Barriers to Equality (Mary Rowe,
1990)
2
Intersectionality is a term which refers to the interconnected nature of different aspects of a person’s identity andhow together they can affect, determine and compound a person’s experience of discrimination.

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Recruitment and selection
Equality is an important part of our recruitment and selection policies and processes. We
therefore require all those undertaking selection decisions to have appropriate and up todate training. Throughout all aspects of our recruitment and selection process we shouldreflect the need to promote equality, encourage diversity and strive for greater inclusion.
Advertisements, whether internal or external (this includes all media – e.g., printed andonline, visual or non-visual) must not indicate or appear to indicate an intention tounjustifiably discriminate on the grounds we have identified within this policy. This means,for example, thinking very carefully before applying age criteria, specific experience andqualifications, restricting flexible working, defining personality type or communicationstyle.
Given we want diverse applicants, we must not confine our advertising to areas,
publications or sites which would undermine this or unjustifiably exclude or
disproportionately reduce our pool.
All advertisements for British Council jobs or placements should reflect our commitment toequality through the following indicative statement:
The British Council is committed to policies and practices of equality, diversity andinclusion across everything we do. We support all staff to make sure their behaviour isconsistent with this commitment. We want to address under representation andencourage applicants from under-represented groups, in particular, but not exclusively, on
grounds of ethnicity and disability. All disabled applicants who meet the essential criteria
are guaranteed an interview and we have Disability Confident Employer Status. We
welcome discussions about specific requirements or adjustments to enable participationand engagement in our work and activities.

Performance management
Our Equality Policy applies to performance management and related development
including succession planning, career breaks, secondments and other opportunities.
It becomes meaningful if all staff consider how equality, diversity and inclusion can add
value to their work. A related performance objective and/or development objective canhelp achieve this and close the gap between what we say and what we do. Employees
and line managers are encouraged to consider this as part of the performance
management cycle.
Evaluation, reporting and moderation of staff performance should be based solely on
evidence. It should not be based on stereotypes or assumptions or affinity bias. For
example, evaluation related to women’s mobility or length of future service, or the suitabilityof people of particular ethnic origins to undertake specific jobs would be inappropriate.

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Primary grounds
The British Council does not have separate policies to cover different areas of diversity. It has a
primary but not exclusive focus on the following grounds, an increasing number of which aresupported by guidance documents for staff. These are referred to in brief below:

Age
We believe it is positive to have a workforce of different generations and ages and toencourage the contributions of children, young people and adults of different ages, acrossthe range of our work, as appropriate. We also believe there is much to gain from anintergenerational approach to both our internal and external work, where people areencouraged to learn from those with different life experience.
Whilst young people are sometimes described as a priority audience for us, because of ourextensive work in the education sector, this should never imply that older people are notalso our priority.
We must avoid age discrimination by implication – for example, by implying ‘future leaders’ arealways young people (they usually will be, but in some instances, they may be disabled people
who have taken a longer and/or different route through education and training, or older people
in some contexts – maybe for socio-economic reasons or cultural/geographical reasons).
Chronological age should not be used as a criterion, either directly or implicitly, where this is
not justified. Our Age Criteria Guidance can help ensure there is no ill-considered andinappropriate age criteria applied to our jobs or our programmes or other opportunities.
By requiring employees, partners and suppliers to abide by our Safeguarding Policies wecan ensure safety and dignity for children and adults at risk of harm.
In the UK and some other countries where we operate there is no default retirement age.
This contributes to ensuring ageing does not lead to reduced opportunities and supports theemployment of colleagues regardless of their age. It promotes inclusion and the learningthat comes from working with people of different ages.
Our proposed guidance on Menopause in the British Council will address someintersections between age and gender. Human Resources are planning to work on
introducing a Menopause Policy during 2022.

Disability
We recognise disability as a broad concept that includes physical, sensory, learning andmental health issues and long-standing and fluctuating health conditions e.g., HIV/AIDS
and cancer. We strive for disability inclusion, recognising the skills and expertise many
disabled people hold and the richness of experience this brings to our work and to cultural
relations.
Language around how to refer to disabled people is contested. Where possible we use
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8‘disabled people’ in line with the social model of disability. In some countries the term
‘disabled people’ is not recognised as positive and the term ‘people with disabilities’ may be
preferable. If in doubt, talk to people and see what terminology they prefer to describe
themselves.
We acknowledge that people are often disabled because of interacting factors, including
cultural and religious attitudes, social issues, and physical and systemic barriers. They arecommon across the world and result in marginalisation and lack of access to full humanrights.
We are committed to addressing unjustified discrimination against and promoting theinclusion of disabled people in our workforce and work and public life.
We aspire to address this by consciously identifying and removing barriers, making
adjustments and promoting the social model of disability alongside the recognition of otherempowering and rights-based models and increasing awareness of interacting factors.
Our Promoting Inclusion: Disability Equality Guide is a resource for all our staff that
supports this.

HIV and AIDS
Given the climate of fear that exists around HIV and AIDS worldwide and its global
prevalence, we recognise the unique nature of this illness. In partnership with the Foreign
Commonwealth and Development Office we have a policy that reaffirms we will notdiscriminate against applicants or employees who are Human Immunodeficiency Virus
positive (HIV+).
Our HIV and AIDS Policy outlines the support that will be provided to colleagues and theirfamilies. It confirms our commitment to trying to maintain a safe environment free fromharassment or other forms of discrimination based on HIV/AIDS.
It should be noted that under UK law and some other legal systems, those with HIV or
AIDS are protected against unjustified discrimination from the point of diagnosis.

GenderWe are committed to tackling gender discrimination. Our focus is on promoting equality anderadicating unjustified discrimination in relation to women and girls who frequently
experience social and economic disadvantage, negative attitudes, alienation, abuse andviolence worldwide.
Unjustified discrimination as a result of pregnancy is particularly prominent and we haveadopted various organisational policies, for example on maternity, paternity, adoption andleave for fertility treatment as a means of countering this 3.
We recognise that dependant responsibilities predominantly fall upon women, with women
3

Policies differ by country / location so please refer to HR SharePoint site or local country terms and conditions.

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9globally doing at least twice as much unpaid care work as men4.
We also seek to address inequalities experienced by men and boys and seek ways toensure that they are not disadvantaged by, or underrepresented and excluded from, thework that we do.
We recognise and seek to eradicate unjustified discrimination that people are subjected tobased on their gender reassignment, or perceived gender reassignment, or because they
are intersex, or hold a non-binary gender identity which may include being gender fluid. We
make relevant guidance available to attune people to the challenges faced by transgenderand intersex people and offer appropriate support and interventions within the workplaceand in our activities. We aim to enable everyone to be recognised and referred to as theywish and to meaningfully and effectively respond to any concerns and issues raised.

Race / Ethnicity and Culture
Racial discrimination includes less favourable treatment based on nationality, ethnic andnational origins, skin colour and other physical markers. It interacts with religion andculture and includes caste and tribe.
We believe that our work is enriched by the different racial / ethnic, cultural groups andtravelling communities we engage with and that cultural relations has an important role toplay in mutual understanding and exchange between different racial / ethnic and culturalgroups.
We know that conflict based on ethnic, cultural and other factors, including statelesspeople, asylum seeker and refugee status, continues to exist and undermines inclusion.
We require all employees, partners and suppliers to ensure no unjustified discrimination on
grounds of race / ethnicity and to promote positive and equitable relations between different
races / ethnicities and cultures. We have a Race Equality Guide to help ensure this.
Language can be an important contributor to reinforcing power structures. We should
ensure that the languages spoken in British Council offices, in our materials and on our
programmes enable people to feel connected and informed rather than isolated or
excluded. We should take care not to expect high levels of English for all roles and shouldseek to encourage and protect minority languages where appropriate.
Our commitments to anti-racism and to decolonisation helps ensure we are working pro-actively
towards race equality as set out in our Anti-Racism Action Plan. As we are the British Council
we need to be especially attuned to our history, including the legacy of empire and the impact
this might have on people from other parts of the world and be open about acknowledging thisin our work.

4

Source: Oxfam International, 2021 ‘Why the majority of the world’s poor are women’

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Religion and Belief
We value and respect the different religions / beliefs held by staff and the external contacts
and communities in which we operate, including those who hold no religion or belief.
We try to ensure that religious / belief needs, and preferences, are met and our Religion
and Belief Guide acts as a resource to support our understanding and to promote related
good practice as well as it acting as a helpful reference point when issues emerge.
We know that in some contexts, the religion / belief of staff members’ partners or extended
family (where this differs from the staff member and/or from the majority in country) mightmean particular support or guidance is needed.
In many countries we provide a dedicated faith or quiet room for prayer, meditation orreflection. In some, we make provision, as required, by the flexible use of our facilities,
and take other actions. This includes supporting staff who are fasting during the Holy
Month of Ramadan and adjusting timetabling (for example) to take account of religious
obligations.
Where existing work requirements conflict with particular cultural and religious needs, we
carefully consider whether it is reasonably practical to vary or adapt such requirements toenable them to be met. Requests for the accumulation of annual leave or unpaid leave toundertake pilgrimage; or to take unpaid leave or exchange public holidays for other HolyDays of Obligation such as Eid, Yom Kippur, Diwali or Guru Nanak, require constructive
consideration. Such consideration should pay due attention to the intersection of socioeconomic background. For example, if unpaid leave is unaffordable, it may be appropriate
to vary or adapt work requirements to accommodate cultural or religious needs.
We are aware that some laws and cultures are particularly hostile towards religious
minorities. We seek to offer a supportive environment to all colleagues and customers
regardless of their religion / belief and working context.
We hold that developing a better understanding of other people’s religions and beliefs willcontribute to improved cultural relations.

Sexual Orientation
We are committed to supporting people of diverse sexual identities including lesbian, gay,bisexual, questioning, asexual, heterosexual and others to feel included and valued and to
tackling discrimination and harassment based on sexual orientation.
We believe all colleagues have the right to be themselves at work without having to beconcerned about sharing aspects of who they are.
Whilst we respect the right of individuals to be open, or otherwise, about their sexual orientation
we recognise that sexual minorities can face especial challenges and be fearful of doing so in
the workplace and beyond, due to homophobia and heterosexism, as well as persecution.
We support everyone working with, or for the British Council to understand that negative
messages or stereotypes, based on actual or perceived sexual orientation, arewww.britishcouncil.org

11unacceptable and inconsistent with our commitment to equality, diversity and inclusion.
We want our workplace to be open and inclusive and a safe space for staff regardless of
their sexual orientation. Our Promoting Inclusion Guide on Sexual Orientation acts as aresource to support understanding and to promote related good practice.
We are aware that some laws and cultures are particularly hostile towards sexual
minorities. Such hostility is sometimes intensified when same sex couples have children /dependants. We seek to offer a supportive environment to all colleagues and customers
regardless of their sexual identity and working context.

Socio-economic background
Employment, education, the quality and nature of health care, housing, access tointernational opportunities and our services, for example, are all significantly determinedby socio-economic background. Socio-economic inequality leads to discrimination,
marginalisation and reduced opportunities. It is a global issue needing attention.
As a result, our refreshed EDI Strategy has established socio-economic background as across cutting area, given the limited formalised attention given to it previously.
As part of our commitment to demonstrating the social value of our work, we aim toincrease employment related opportunities for people from socially disadvantaged
backgrounds, as well as opportunities to participate in our programmes, events, classes
and activities wherever possible.
We will strengthen this commitment through a related action plan and guidance to help
widen participation in employment and our activities for socio-economically disadvantaged
people (in particular young people, including those with characteristics that often
compound disadvantage, most notably disability).

Equality and pay
We have a commitment to a pay system that is transparent and based on objective criteria. This
includes a commitment to transparency and fairness in the allocation of bonuses, allowances
and any other aspects of reward and renumeration.
Equal pay, free from gender or other unjustified bias, for the same or broadly similar work(that is, for work that rates as equivalent and for work of equal value), operates within the
British Council.
We will continue to undertake regular UK equal pay audits and related equality pay gap
assessments with an intersectional dimension and comply with required external reporting
and look to extend these beyond the UK.

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12Bullying and harassment
Bullying and harassment are about misuse of power and should not be a part of ourworking culture or practices. There can sometimes be a tendency for incidents ofbullying and/or harassment to be ‘swept under the carpet’ which means they are ignored
and not treated seriously as they should be. This is counter to the organisational culture
we aspire to and all staff are encouraged to speak up using relevant procedures (seesection on the Speak Up policy below).
Bullying is offensive, intimidating, malicious and/or insulting behaviour, or an abuse or
misuse of power, that undermines, humiliates, or injures the recipient.
Harassment, in general, is unwanted conduct affecting someone’s dignity. It can be
related to age, disability, ethnicity / race, gender, religion or belief, sexual orientation, or
any personal characteristic of the individual. It may involve persistent incidents or an
isolated one. The crucial aspect is that the actions or comments are deemed to be
demeaning and unacceptable to the recipient and create a hostile environment.
Bullying and harassment can manifest in a variety of ways, including by one member ofstaff to another of a different or equivalent level / pay band, or by one group of staff to anindividual member of staff, or an external contact. If bullying or harassment involves issuesof gender including transgender, sexual orientation, marital - including civil partnership status, caring responsibility, race / ethnicity, religion / belief, political belief, age or disability,
relevant legislation may apply.
Our Equality Policy, Bullying and Harassment and other policies require each employee
to guard against all bullying and harassment and with, for example, training interventions,
support a dignifying work environment and service delivery culture.

Grievances and/or Concerns
It is hoped that personal concerns can be handled and indeed resolved informally, at leastin the first instance. Employees who have a concern may wish to contact Human
Resources, a Trade Union or Staff Association representative, Teachers’ representative ora trusted colleague for support. All concerns must be handled in confidence.
External contacts wishing to complain should use the British Council Complaints Policy.
Any employee who feels that the treatment they have received is not in keeping with ourEquality Policy has a right to raise this under the Grievance Policy and Procedures.
Employees must not be intimidated, discriminated against or treated differently for raising a
concern, complaining or assisting in an investigation. If this happens it could amount tovictimisation which maybe unlawful within the terms of the relevant legislation and goesagainst this and other related policies and their application.

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Speaking Up
The Speak Up Policy aims to protect the British Council by providing a framework thatencourages and enables employees to raise concerns about serious malpractice.
These concerns may be about financial malpractice, breaches of the law, serious
misconduct by another person and breaches in the areas of health and safety, or indeed
diversity. Built into the policy is an assurance that there will be no risk to the person raisingsuch concerns if actions are based on good faith.

Responsibilities
As an organisation representing and promoting the UK’s achievements internationally, it
is particularly important that we reflect contemporary UK society, good workplace andcustomer service practices. We must also be open to learning from and applying thegood practices and approaches of others. We must consistently apply our corporate
values.
We must adhere to relevant legislation and behavioural standards and recognise that, asa general principle of law, employers may be liable for acts of unjustified discriminationcommitted by their employees in the course of their employment.
Putting this policy into practice is the responsibility of every individual employee. All staff,
including those working from home, whether on full-time, part-time, indefinite, fixed or
temporary contracts, regardless of length of service, are responsible for playing their fullpart in adhering to the policy.
This means becoming familiar with it, and its requirements, and carrying them out, as wellas critically examining attitudes to ensure that unjustified discrimination is not allowed toaffect judgement.
The law and the existence of an Equality Policy cannot by themselves prevent unjustified
discrimination. It is therefore crucial that everyone takes personal responsibility to help
ensure that the work environment, consistent with cultural relations, respects the dignity of
everyone and in broad terms, values the differences that exist between diverse people andcultures. As a cultural relations organisation, we should be adept at working with difference
and able to identify and make the best use of what we share and have in common.
All staff will continue to be supported to understand how unjustified discrimination can takeplace and to avoid this and any other action that might undermine respect and inclusion.
This will be achieved through, for example, ongoing awareness and training initiatives, using the
British Council’s Diversity e-learning materials and engaging with the range of developments
initiated by the Diversity Unit and other parts of the organisation.
All managers are responsible for ensuring that this Equality Policy is implemented in theirteams and departments and for dealing with matters arising from it. As part of fulfilling this
responsibility, managers must take care to deal effectively with complaints of unjustified

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discrimination, harassment, bullying and victimisation. They must not make assumptions
that complaints are a result of ‘over-sensitivity’ and must take them seriously and deal withthem sympathetically, with integrity and generally in a way that is consistent with principles
of natural justice.
We are all required to ensure that external contacts including suppliers are aware of thispolicy and their obligations to work and operate within its parameters as appropriate. The
Equality / Equal Opportunity Policy or other similar policy of contractors, where these exist,
must be reviewed before entering into an agreement with them, and if necessary, a related
discussion undertaken.
Any employee who unjustifiably discriminates or induces others to do so may be subject
to disciplinary action. In addition, any employee who fails to co-operate with measures
promoting equality of opportunity / access / choice / outcomes in the context of British
Council activity may be subject to such action.
The British Council opposes any conduct or activity by any individuals it employs which iscontrary to its Equality Policy, or which is likely to bring it into disrepute in relation to EDI
issues.
Nothing in this Equality Policy is intended to interfere with the legitimate freedom of artistic
or intellectual expression, investigation or discussion. We live, however, in a world ofincreasing polarity around political and cultural issues, often heightened on social media.
As employees we must all take personal responsibility for abiding by our Code of Conduct
and Social Media Policy.
It is understood that there can often be a fine line between what is acceptable andunacceptable, and each case will be considered on the individual circumstances.
Accountability is an important part of ensuring improvement. However, the Diversity Unit
does not advocate a zero-tolerance approach to discriminatory or unacceptable behaviour.
This is especially important for an organisation as geographically, culturally andlinguistically diverse as ours.
A zero-tolerance approach is often associated with meting out the most severe punishment
possible for any breach, or a punishment of every wrongdoing. It does not allow for
individual culpability or response, or extenuating circumstances, context or history. It is ablunt instrument for a complex area, and we do not believe it is an effective tool.
This does not mean accountability should be watered down. It should not and must not.
Unjustified discrimination has no place in our cultural relations organisation and ourcommitment to equality, diversity and inclusion must be made clear to all who work with us
and for us and all who use our services.

Monitoring, evaluation and legal compliance
Monitoring and evaluation help us assess the effectiveness of our Equality Policy and EDI
Strategy and to this end we have numerous mechanisms in place.

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For example, we monitor the equality profile of our UK-contracted staff and are extending
this outside the UK to help capture data on the equality profile of all British Council staff.
We are developing an EDI data dashboard and will review EDI data through Quarterly
Business Area Reviews (QBRs). This supports the evidence-based approach the Diversity
Unit strongly encourages.
Strategy 2025 has key performance indicators (KPIs), some related to EDI which will
provide relevant data as will the results of our Diversity Assessment Framework.
We comply with the requirement under Article 55 of the Fair Employment and Treatment(Northern Ireland) Order 1998 to complete a review of employment composition andpractice every three years and report on this. This is to ensure that Roman Catholics andProtestants enjoy fair participation in employment in Northern Ireland. We also undertakean annual progress report and a five-year review against our obligations under Section
75, Northern Ireland Act 1998.
We fulfil our obligations under the Welsh Language Act 1993 supported by the British Council
Welsh Language Scheme.

Communication
A copy of the Equality Policy is made accessible to all employees via the web and intranet sites.
Requests for this policy in alternative formats are welcomed and every effort will be made tomeet them.
All employees, including newly appointed ones must be made aware of this policy and theirindividual and wider organisational responsibilities for achieving equality objectives. In
addition, this policy and supporting EDI Strategy and/or its principles, in keeping with ourmainstreaming endeavours, must be referred to as appropriate. This includes in relevant
training courses, guidance notes and manuals, throughout the procurement process andthe induction of consultants and contractors and as part of operational work.

Review
We undertake a formal review of this policy at least once every three years and tocommunicate changes organisation-wide. Responsibility for this lies with the Global Headof Equality, Diversity and Inclusion. Next review date is January 2025. To obtain further
copies of this policy, or if you have any questions or comments about it, please contact
the Diversity Unit.

Fiona Bartels-Ellis
Global Head of Equality, Diversity and Inclusion
January 2022

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