Document Sample


This document sets out the actions which Student Loans Company (SLC) intends to take in order to progress the
implementation of our Single Equality Scheme for 2009 – 2012. The overarching objective of the Single Equality
Scheme is to ensure that employees of SLC and its customers are treated equally, irrespective of age, disability,
gender, gender identity, race, religion or belief or sexual orientation. In addition this document sets out the
measures which SLC intends to take to ensure that the services it provides are appropriately tailored to customers
with disabilities. Progress on achieving objectives and actions will be monitored on a regular basis by SLC’s
Equality Forum.

The actions in this document are set within three overall aims:

    1. for SLC to continue to be an equal opportunities employer;

    2. to make customer access to SLC’s services easier; and

    3. to ensure that providers of services to SLC meet our procurement criteria for all equality areas.

Actions are further subdivided within each overall aim. In addition a colour coding system has been used to
designate the timescales by which each action should be completed as follows:

    1. Green designates an action is a long term objective;

    2. Orange designates an action is a medium term objective;

    3. Yellow designates an action is high priority and is to be completed in the short term; and

    4. Blue designates an action is ongoing.

If you would like to give us feedback on our Single Equality Scheme and Action Plan or wish to request copies of
this document in alternative formats, please contact Shareen Auckbarallee, Legal and Compliance Manager on
0141 306 2068 or e-mail

Reference                       Objective                            Activities likely to improve performance          Legislative       Priority   Owner
AIM 1: For SLC to continue to be an equal opportunities employer and to ensure that no employee or job applicant receives less favourable treatment
on grounds of gender, marital status, disability, race, colour, nationality, ethnic origin, religion or belief, sexual orientation, family circumstances or
age, or are placed at a disadvantage by imposed conditions or requirements which cannot be shown to be justified. For SLC to continue to develop,
monitor and update existing policies and procedures which reflect SLC’s commitment to all of the above.

[A] General

A1            To treat all employees fairly, with dignity and   Ensure that employees (new and existing) receive          Disability,            Ongoing   Learning &
              respect. To provide a supportive and              awareness training on diversity and on the positive       Gender,       Race
                                                                                                                                                           ment and
              welcoming working environment and to              equality duties imposed by legislation and SLC’s          and         Equality             Communic-
              ensure that the opportunities we provide are      policies and procedures.                                  Legislation                      ations
              open to all.

A2            As above                                          Maintain SLC’s commitment to the standards required       Disability,            Ongoing   All
                                                                of the Double Tick status from Job Centre Plus.           Gender,       Race
                                                                                                                          and         Equality

A3            As above                                          Maintain our Prayer Room for employees.                   Race           and     Ongoing   Facilities

A4            As above                                          Maintain our supportive approach to flexible working      Disability,            Ongoing   HR /
                                                                requests.                                                 Gender,       Race               Business
                                                                                                                          and         Equality             Owners

A5            As above                                          If any employee advises us that they are disabled we      Disability     and     Ongoing   HR /
                                                                will undertake reasonable adjustments to ensure that      Equality                         Business
                                                                they remain in employment, as advised by our              Legislation                      Owners
                                                                occupational health doctor.

A6            As above                                          Maintain the training / awareness of managers in          Disability,            Ongoing   Legal and
                                                                respect of equality impact assessments, the general       Gender,       Race               / Learning
                                                                equality duties and the implications of these for their   and         Equality             and
                                                                work.                                                     Legislation                      Developme-
                                                                                                                                                           nt / Change

Reference                      Objective                     Activities likely to improve performance              Legislative         Priority    Owner
A7          As above                                    SLC’s Legal and Compliance Team will continue to        Disability,            Ongoing    Legal &
                                                        review SLC’s policies and procedures relative to        Gender,       Race
                                                        employees to ensure compliance with the latest          and         Equality
                                                        legislation.                                            Legislation

A8          As above                                    Recruit our Diversity Manager vacancy.                  Disability,            Short      HR / Legal
                                                                                                                Gender,       Race     term       Compliance
                                                                                                                and         Equality

A9          As above                                    Review internal procedures to identify barriers which   Disability     and     Short      HR / Legal
                                                        may prevent people from applying for jobs and           Equality               term       Compliance
                                                        working to the best of their abilities.                 Legislation

A10         As above                                    Through monitoring and analysis we will address the     Gender         and     Long       HR/Unions/
                                                        causes of any gender pay gap and take action to         Equality               term
                                                        address any issues identified.                          Legislation

A11         To ensure that our buildings are safe and   Consider fully any reasonable adjustments required to   Disability,            Short      Facilities /
            accessible to all.                          make our buildings more accessible.                     Gender,       Race     term       Procurem
                                                                                                                and         Equality              ent

A12         As above                                    Arrange for random anonymous testing of our             Disability     and     Long       Facilities
                                                        premises to ensure compliance with our duties.          Equality               term

A13         To ensure that our working practices are    This is a general overarching objective. The steps to   Disability,            Long       Facilities /
            accessible to all employees.                be taken to implement this objective are set out        Gender,       Race     term       Procurem
                                                        throughout this action plan, however SLC will           and         Equality              ent
                                                        continually consider fully any reasonable adjustments   Legislation
                                                        required to make our working practices more

A14         Annual reporting                            Produce an annual report on the implementation of       Disability,            Long       HR /
                                                        our Equality Scheme and a summary of our progress       Gender,       Race     term       Communic
                                                        including adherence to our gender equality duty with    and         Equality              ations
                                                        key points on how to address gaps.                      Legislation

Reference                    Objective                           Activities likely to improve performance                Legislative         Priority    Owner
[B] Equality Forum

B1          SLC’s Equality Forum will continue to update,   We ensure that the Equality Forum is responsible for      Disability,            Ongoing    Equality
            maintain, monitor and review SLC’s Equality     representing all diversity groups and that the Public     Gender,       Race                Forum
            Scheme.                                         and Commercial Services Union is represented on the       and         Equality
                                                            Equality Forum.                                           Legislation

B2          As above                                        Ensure that identified adverse impacts are addressed      Disability,            Ongoing    Equality
                                                            by liaising with managers and seeking feedback in         Gender,       Race                Forum /
                                                            accordance with SLC’s monitoring techniques set out       and         Equality              Business
                                                            in section C.                                             Legislation                       Owners

B3          As above                                        Ensure that the Equality page features on the intranet    Disability,            Short      Equality
                                                            home page on a quarterly basis to ensure exposure.        Gender,       Race     term       Forum /
                                                                                                                      and         Equality              Commu-
                                                                                                                      Legislation                       nicatons

B4          As above                                        SLC will join the Equality Exchange which has been        Disability,            Medium     Equality
                                                            established by the Equal Opportunities Commission.        Gender,       Race     term       Forum
                                                            This forum provides seminars on the latest                and         Equality
                                                            developments in equality and diversity and enables        Legislation
                                                            the exchange of ideas and best practice. A member
                                                            of the Equality Forum will attend this.

B5          As above                                        Quarterly meetings and the production of reports of       Disability,            Long       Equality
                                                            the Equality Scheme to the Finance and Governance         Gender,       Race     term       Forum
                                                            Board and the Remuneration Committee. This also           and         Equality
                                                            ensures regular review of the aims and objectives of      Legislation
                                                            the Equality Scheme and the most effective use of
                                                            monitoring to ensure these are being met.

B6          As above                                        We will maintain a register of equality impact            Disability,            Long       Equality
                                                            assessments and publish regular updates.                  Gender,       Race     term       Forum /
                                                                                                                      and         Equality              Commu-
                                                                                                                      Legislation                       nicatons
B7          As above                                        Ensure we encourage positive images of employees          Disability     and     Long       Communic-
                                                            from diverse backgrounds in company literature,           Equality               term
                                                                                                                                                        Team /
                                                            publications and communications.          Aim to have     Legislation                       Equality
                                                            regular equality features in our internal magazine, the                                     Forum
                                                            Reporter and the Pulse.

Reference              Objective        Activities likely to improve performance             Legislative         Priority    Owner
B8          As above               The Equality Forum will liaise with various equality   Disability,            Long       Equality
                                   groups to ensure we are complying with best practice   Gender,       Race     term       Forum
                                   including: [the Equality Challenge Unit (which         and         Equality
                                   supports the higher education sector to realise the    Legislation
                                   potential of all employees and students); Stonewall;
                                   West of Scotland Regional Equality Council; Glasgow
                                   Anti-Racist Alliance, and the Equality and Diversity

B9          As above               The Equality Forum will host an annual equality        Disability,            Long       Equality
                                   awareness day to highlight the importance of the       Gender,       Race     term       Forum /
                                   Equality Scheme and the day to day implementation      and         Equality              HR /
                                   of the Equality Scheme.                                Legislation                       Commu-

Reference                    Objective                           Activities likely to improve performance               Legislative         Priority    Owner
[C] Monitoring Techniques and Implementation

C1          SLC recognises the need to develop improved     We will maintain our Whistleblowing Policy which         Disability,            Ongoing    HR /
            reporting mechanisms to capture relevant        enables employees and contractors of SLC to draw         Gender,       Race                Commu-
            data and information for monitoring and         our attention to any malpractice or unlawful conduct     and         Equality              nications
            measuring equality. This will enable the        which they suspect is taking place at work (including    Legislation
            assessment of the impact of the Equality        bullying and harassment).
            Scheme on different groups of employees and
            job applicants. SLC will adopt a systematic
            approach to evidence gathering, monitoring,
            measurement, analysis and reporting on the
            Equality Scheme. Responsibility for this will
            be assigned to the Equality Forum.

C2          As above                                        Continue to audit our pay structures and pay practice    Disability,            Ongoing    HR
                                                            on an annual basis to identify any equal pay issues.     Gender,       Race
                                                                                                                     and         Equality

C3          As above                                        SLC will introduce an Employee Communications            Disability,            Short      Commu-
                                                            Strategy which will ensure that all our communications   Gender,       Race     term       nications
                                                            are provided in accessible formats regardless of         and         Equality
                                                            disability or language ability.                          Legislation

C4          As above                                        Increase levels of declaration of equality-related       Disability,            Short      HR
                                                            employee information by providing the option for all     Gender,       Race     term
                                                            employees      to  complete    an     equality-related   and         Equality
                                                            questionnaire, where an option of “prefer not to say”    Legislation
                                                            will be included.

C5          As above                                        A number of techniques will be deployed in the           Disability,            Long       All
                                                            monitoring of the Equality Scheme. These include:        Gender,       Race     term
                                                                                                                     and         Equality
                                                            1.   data analysis;                                      Legislation
                                                            2.   audits;
                                                            3.   reviews by the Equality Forum; and
                                                            4.   equality impact assessments.

Reference              Objective         Activities likely to improve performance             Legislative         Priority    Owner
C6          As above               Enhance our current diversity monitoring (gender,       Disability,            Long       HR /
                                   disability and ethnic origin) of data to identify any   Gender,       Race     term       Assistance /
                                   possible unlawful discrimination in recruitment,        and         Equality              Collections
                                   performance appraisal, or promotion and to monitor      Legislation                       / Customer
                                   the number of employees from diverse groups. As                                           Services /
                                   part of this we will monitor, by reference to diverse                                     Marketing /
                                   groups, the number of employees who:                                                      ICT

                                       1. apply for employment, training and promotion
                                          within SLC;
                                       2. complain with respect to performance
                                          assessment procedures;
                                       3. are the subject of disciplinary procedures;
                                       4. cease employment with SLC;

                                   in order to identify any trends.

Reference                    Objective                            Activities likely to improve performance                  Legislative         Priority    Owner
[D] Employees of SLC

D1          We will develop our approach to employee        SLC will maintain an Equality section within the             Disability,            Ongoing    Equality
            recruitment and promotion, to ensure that the   intranet which will be accessible to all employees           Gender,       Race                Forum /
            operational rules are clear and transparent     setting out our policies and providing an “Equality E-       and         Equality              Online
            and that they are reviewed to help ensure       mail In-box” to enable employees to submit queries           Legislation                       Services
            they would not inadvertently disadvantage an    and concerns to the Legal and Compliance Team.
            employee or external applicant on any
            grounds other than their relative skills and
            ability to undertake the position.

D2          As above                                        SLC will maintain its 24/7 confidential employee             Disability,            Ongoing    HR
                                                            counselling service which provides free access to a          Gender,       Race
                                                            wide range of specialist support and information.            and         Equality

D3          As above                                        SLC will maintain a Childcare Voucher Scheme in              Gender         and     Ongoing    HR
                                                            accordance with legislative requirements.                    Equality

D4          As above                                        SLC will continue to implement enhanced maternity            Gender         and     Ongoing    HR
                                                            and paternity leave arrangements including parental          Equality
                                                            leave   for      employees       who     have     parental   Legislation
                                                            responsibilities as a result of a child born or adopted.

D5                                                          SLC will include in all jobs a requirement to implement      Disability,            Short      HR
                                                            equality and respect diversity, with all job applications    Gender,       Race     term
                                                            being assessed against this requirement.                     and         Equality

D6          As above                                        Implement a positive action initiative through the           Disability,            Long       HR /
                                                            encouragement of applications for jobs from people           Gender,       Race     term       Commu-
                                                            from diverse backgrounds, for example through                and         Equality              nications
                                                            advertising of employment opportunities in specialist        Legislation

D7          As above                                        Ensure that job details are available and job                Disability, Race       Long       HR /
                                                            applications are acceptable in a variety of formats,         and        Equality    term       Commu-
                                                            including Braille, large print, audio and mini-com.          Legislation                       nications

Reference              Objective         Activities likely to improve performance                 Legislative         Priority    Owner
D8          As above               SLC will interview all disabled job applicants who, at      Disability   and       Long       HR
                                   the short-listed stage, show that they meet the             Equality               term
                                   requirements to do the job in accordance with the Job       Legislation
                                   Centre’s Double Tick standard.

D9          As above               Refer any employee who advises SLC that they are            Disability     and     Long       HR
                                   suffering from any disability which affects their role as   Equality               term
                                   defined in the Disability Discrimination Act 1995 to        Legislation
                                   SLC’s Occupational Health provider for a consultation
                                   with a view to assisting the employee as appropriate.

D10         As above               SLC intends to introduce additional support from IT to      Disability     and     Long       ICT
                                   employees with visual impairment or dyslexia                Equality               term
                                   including specialised training and/or equipment such        Legislation
                                   as voice recognition software.

D11         As above               SLC will support peer networking and development            Disability,            Long       Equality
                                   amongst employees from diverse backgrounds by               Gender,       Race     term       Forum /
                                   enabling employees to attend:                               and         Equality              Business
                                                                                               Legislation                       Owners
                                       1. external networking events hosted by
                                          interested groups (e.g. Glasgow Disability
                                          Alliance); and

                                       2. internal networking events and forums.

Reference                     Objective                            Activities likely to improve performance                Legislative         Priority    Owner
Aim 2: To make customer access to SLC’s services easier

2(A)        To ensure that no customer receives less          Maintain ongoing training for employees to deal with      Disability     and     Ongoing    Customer
                                                                                                                                                          Assistance /
            favourable treatment on grounds of gender,        customers who have disabilities.                          Equality
            marital status, disability, race, colour,                                                                   Legislation                       Services /
            nationality, ethnic origin, religion or belief,                                                                                               Collections
            sexual orientation, family circumstances or                                                                                                   / ICT
            age, or are placed at a disadvantage by                                                                                                       nt / Product
            imposed conditions or requirements which                                                                                                      Marketing
            cannot be shown to be justified. This includes                                                                                                /Customer
            access to SLC documentation and our                                                                                                           insight/HR
            website. We also aim to treat all customers
            fairly, with dignity and respect.

2(B)        As above                                          We will continue to adhere to DSA guidance.               Disability     and     Ongoing    Customer
                                                                                                                                                          Assistance /
                                                                                                                        Legislation                       Services /
                                                                                                                                                          / ICT
                                                                                                                                                          nt / Product
2(C)        As above                                          Maintain our corporate policy on how to deal with         Disability,            Ongoing    Customer
                                                                                                                                                          Assistance /
                                                              customers who are finding it difficult to meet their      Gender,       Race
                                                              commitments to the SLC due to mental illness,             and         Equality              Services /
                                                              incapacity or physical disability.                        Legislation                       Collections
                                                                                                                                                          / ICT
                                                                                                                                                          ment /
2(D)        SLC will ensure that the funding application      SLC recognises the importance of DSA to help meet         Disability     and     Ongoing    Customer
                                                                                                                                                          Assistance /
            process in respect of Disabled Students’          the extra costs of studying which students face as a      Equality                          Customer
            Allowance (DSA) is as simple and streamlined      result of their disability. SLC will therefore continue   Legislation                       Services /
            as possible and for purpose.                      the function of SLC’s specialist support team in                                            Collections
                                                              accordance with SLC’s Targeted Support Service                                              / ICT
                                                              Definition document for each academic year, which
                                                                                                                                                          nt / Product
                                                              provides specific support for disabled students. SLC’s                                      Marketing
                                                              specialist support team is subject to constant internal                                     /Customer
                                                              review.                                                                                     insight

Reference              Objective         Activities likely to improve performance                 Legislative         Priority    Owner
2(E)        As above               SLC’s specialist support team will provide a named          Disability   and       Ongoing    Specialist
                                   contact service to individual customers with disabilities   Equality                          Team
                                   at each customer’s request.                                 Legislation

2(F)        As above               Continue the specialist support team’s relationship         Disability     and     Ongoing    Customer
                                                                                                                                 Assistance /
                                   with the Disabled Students Allowance Quality                Equality                          Customer
                                   Assurance Group (DSA-QAG) and PATOSS (the                   Legislation                       Services /
                                   professional association of teachers of students with                                         Collections
                                   specific learning difficulties).                                                              / ICT
                                                                                                                                 nt / Product

2(G)        As above               Ensure that forms, guides and leaflets are available in     Disability     and     Short      Product
                                   a variety of formats, including braille, large print and    Equality               term       Marketing
                                   audio. Ensure SLC’s Customer Support Office is also         Legislation
                                   equipped to deal with contact by telephone, e-mail
                                   and web-chat and mini-com for customers with
                                   hearing impairment.

2(H)        As above               SLC will work with DSA-QAG to carry out an equality         Disability     and     Short      Specialist
                                   impact assessment of the DSA application process.           Equality               term
                                                                                                                                 Team /
                                                                                               Legislation                       Customer
                                                                                                                                 Services /
                                                                                                                                 Marketing /

2(I)        As above               Ensure public access to information and services            Disability,            Medium     Communic-
                                                                                                                                 ations /
                                   provided by SLC.                                            Gender,       Race     term       Customer
                                                                                               and         Equality              Assistance

2(J)        As above               Conduct independent        reviews    of   our   website    Disability     and     Medium     Online
                                   accessibility regularly.                                    Equality               term       services

Reference              Objective        Activities likely to improve performance                 Legislative         Priority    Owner
2(K)        As above               Ensure adequate provisions available for alternate         Disability   and       Medium     Customer
                                                                                                                                Assistance /
                                   methods of contact.                                        Equality               term       Customer
                                                                                              Legislation                       Services /
                                                                                                                                / ICT
                                                                                                                                nt / Product
2(L)        As above               Review our web based application pages to ensure           Disability     and     Medium     Stakeholder
                                   accessibility on a regular basis. Ensure validation by     Equality               term       /
                                   independent bodies.                                        Legislation                       Product
                                                                                                                                and online
2(M)        As above               Carry out equality impact assessments of relevant          Disability,            Long       Change
                                   policies and functions and involve stakeholders in this    Gender,       Race     term       ment with
                                   process. Consider the impact of change requests and        and         Equality              input from
                                   service delivery changes in order to conduct effective     Legislation                       Business
                                   equality impact assessments of same.                                                         Owners

2(N)        As above               Monitor the effectiveness of our services to ensure        Disability     and     Long       Customer
                                                                                                                                Assistance /
                                   that they reach all groups and that people are satisfied   Equality               term       Customer
                                   with our service. Benchmark regularly against other        Legislation                       Services /
                                   organisations.                                                                               Collections
                                                                                                                                / ICT
                                                                                                                                nt / Product
2(O)        As above               SLC will carry out an equality impact assessment           Disability,            Long       Customer
                                                                                                                                Assistance /
                                   each time a substantial change is made to the              Gender,       Race     term
                                   services we offer.                                         and         Equality              Services /
                                                                                              Legislation                       Collections
                                                                                                                                / ICT
                                                                                                                                ment /
                                                                                                                                Marketing /

Reference              Objective        Activities likely to improve performance             Legislative      Priority    Owner
2(P)        As above               Gather the views of disabled customers, sponsors and   Disability   and    Long       Customer
                                   stakeholders on our help lines and whether they        Equality            term       Insight
                                   provide an effective service.                          Legislation

2(Q)        As above               Take positive action alongside our stakeholder         Disability    and   Long       Stakeholder
                                   colleagues in education to ensure adequate promotion   Equality            term
                                   of our products relevant to those with disabilities.   Legislation                    Business
                                   Ensure those products are adjusted to be fit for                                      services

2(R)        As above               Take positive steps to promote our services as a       Disability    and   Long       Stakeholder
                                   whole to disabled customers. Work with partners to     Equality            term
                                   ensure we are providing our customers with what they   Legislation                    Business
                                   need.                                                                                 services

Reference                     Objective                          Activities likely to improve performance              Legislative         Priority    Owner
Aim 3: To ensure that providers of services to SLC meet our procurement criteria for all equality areas

3(A)         Ensure that contractors providing goods,       Monitor the relevant equality                           Disability,            Ongoing    Procure-
             facilities and services to us meet our         considerations in the procurement process, to           Gender,       Race                ment
             procurement criteria for all equality areas.   ensure that we are meeting the equality duties in       and         Equality
                                                            relation to this function.                              Legislation

3(B)         As above                                       Ensure that suppliers/contractors apply the same        Disability,            Ongoing    Procure-
                                                            equality standards to their own employees as they are   Gender,       Race                ment
                                                            required to exhibit in their dealings with SLC’s        and         Equality
                                                            employees in fulfilling their contracted duties.        Legislation


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