How to ACT Guidance Pillar 1 : Transparency

Making any policy public is the culmination of a series of internal pieces of work, so it can be helpful to think of it as a goal. The idea of complete transparency on DEI topics may feel overwhelming to some firms, however it is good practice and will ensure that the policy is robust. Consider the alternative; a policy that a firm feels is not fit to be shared with stakeholders probably needs some work.

The DEI policy is a place where expectations are set for both the firm and for employees, along with channels for redress and access to solutions. As with any policy creation, the more transparency in how the policy has been written, the more the norms within are established and clear. The policy is not where company values should be set out, but they can be a reference point and contextual background for how the policy has been drafted.

Making policies available to prospective staff is helpful to create a level playing field for applicants, too. Talent is increasingly discerning in choosing where to work, and the working culture is very important to their decision. Prospective staff will review publicly available information, including platforms such as Glassdoor, to form their opinion on a company. Candidates appreciate having curated information on relevant topics, and will notice if there is a lack.

And there are many stakeholder groups including prospective staff that have interest in company reporting on commitments and targets, such as Women in Finance, ethnicity pay gap reporting or other diversity measures. It may take time for firms to deliver meaningful data on some of the commitment areas. Rather than avoid the prospect of reporting, firms can create narrative on processes, internal targets and other movement towards achieving their commitments.

Some form of annual reporting or disclosure requirement is in fact helpful for firms to establish internal channels for data collection and to elevate the issue and create awareness. Because it is likely that initial disclosures will point to a desire for progress, the reporting should also be treated as an opportunity to provide context and next steps alongside the snapshot of data.

A company’s action plan can include areas such as:

• Specific milestones or progress towards targets

• The establishment of groundwork in specific or multiple areas

• The allocation of additional resources

• Efforts to champion particular causes as advocates (internally or externally)

• Specific areas of work that have emerged from employee engagement; and/or

• Issues raised by external stakeholders.