Workforce Race Equality Standard (WRES) Data Report 2015/16 The NHS has introduced a national Workforce Race Equality Standard (WRES) to ensure employees from black and minority ethnic (BME) backgrounds have equal access to employment opportunities and receive fair treatment in the workplace. WRES was developed nationally following recent reports which have highlighted disparities in the number of BME people in senior leadership positions across the NHS, as well as lower levels of wellbeing amongst the BME population. In order to meet the standard the Trust must: 1. Ensure that appropriate data is being collected including demographic statistics from the geographical area we serve, staff survey and other workforce related data. 2. Analyse its position against each indicator, explore any possible issues and publish the data 3. Take steps to close any identified gaps between the treatment of White and BME staff, where this is appropriate. Page 1 of 18
The following table lists the 9 WRES indicators which all NHS organisations are expected to rate their individual data against. This report serves to provide data in response to the 9 criteria and to analyse, identify and consider if any action needs to be taken to close any gaps in equality that may become apparent. Any gaps which the Trust acknowledges should be closed will then form actions which will be included in the Trust s revised Equality Objectives for 2016/17. NHS Workforce Race Equality Standard indicators Workforce indicators For each of these four workforce indicators, the Standard compares the metrics for White and BME staff. 1 Percentage of BME staff in Bands 8-9, Very Senior Managers VSM (including executive Board members and senior medical staff) compared with the percentage of BME staff in the overall workforce 2 Relative likelihood of BME staff being appointed from shortlisting compared to that of White staff being appointed from shortlisting across all posts. 3 Relative likelihood of BME staff entering the formal disciplinary process, compared to that of White staff entering the formal disciplinary process, as measured by entry into a formal disciplinary investigation. 4 Relative likelihood of BME staff accessing non mandatory training and CPD as compared to White staff National NHS Staff Survey findings. For each of these four staff survey indicators, the Standard compares the metrics for the responses for White and BME staff for each survey question 5 KF 18. Percentage of staff experiencing harassment, bullying or abuse from patients, relatives or the public in last 12 months 6 KF 19. Percentage of staff experiencing harassment, bullying or abuse from staff in last 12 months 7 KF 27. Percentage believing that trust provides equal opportunities for career progression or promotion 8 Q23. In the last 12 months have you personally experienced discrimination at work from any of the following? a) Manager/team leader or other colleagues Boards. Does the Board meet the requirement on Board membership in 9. 9 Boards are expected to be broadly representative of the population they serve Page 2 of 18
INDICATOR 1 Percentage of BME staff in bands 8-9, very senior managers VSM (including executive board members and senior medical staff) compared with the percentage of BME staff in the overall workforce. The total number of employees in the Trust on 31 March 2016 was 3, 914. Of these, 3, 695 declared themselves to be of White origin and 184 declared themselves as being of BME origin. 35 employees have not declared or confirmed their ethnic origin. The ESR Data Management Team is undergoing a wide-scale data cleanse and routinely request updates from employees around personal details recorded. Ethnic Group By Headcount By % of overall workforce White background 3, 695 94.41% BME background 184 4.70% Ethnicity Unidentified 35 0.89% TOTAL 3,914 100% This table shows the numbers of employees who identify as White against the numbers of employees who identify as BME by Agenda for Change Pay Band and those in Very Senior Managerial posts (VSM); VSMs includes senior medical staff holding managerial roles and executive and non-executive directors. Pay Band/Role White Employees BME Employees Headcount % Headcount % VSMs 26 89.66% 3 10.35% Band 9 5 100% 0 0.00% Band 8D 7 100% 0 0.00% Band 8C 19 100% 0 0.00% Band 8B 43 100% 0 0.00% Band 8A 71 100% 0 0.00% Band 7 371 98.93% 4 1.07% Band 6 618 98.41% 10 1.59% Band 5 818 95.34% 40 4.66% Band 4 245 99.19% 2 0.81% Band 3 578 99.14% 5 0.86% Band 2 629 98.28% 11 1.72% Band 1 112 95.73% 5 4.27% Totals 3542 80 NB: the chart above excludes medical staff who are not in managerial roles Page 3 of 18
WRES states that for Indicator 1 that compares ethnicity across pay bands, Trusts should seek to ensure that staff response rates are similar for AfC Bands 8-9/VSM as for staff response rates as a whole and are as high as possible. In many Trusts 95% and above is the goal. The data above clearly indicates that there are no staff in Bands 8a 9 from a BME background. Just 3 of 29 Very Senior Managers are from a BME background. Of 174 posts at Bands 8a to 9 plus VSM, only 3 of these are held by a BME employee. This equates to 1 in every 21.608 of post-holders at Bands 8a to 9, being White British background and 1 in 61.333 being of BME background. The EDSG considered that the BME representation in the Trust workforce is broadly representative of the local population. Page 4 of 18
INDICATOR 2 Relative likelihood of BME staff being appointed from shortlisting compared to that of White staff being appointed from shortlisting across all posts. The Trust continuously monitors current recruitment processes and amends these as and when necessary to reflect best practice and revised legislation. The Trust is committed to recruiting fairly and consistently to ensure that the candidate most suitable for the post, based on the required skills and knowledge, is recruited. The Trust has offered formal Recruitment and Selection Training to Managers for a number of years, in line with Trust Policy. The Recruitment and Selection Training is currently under review and is to be relaunched with effect from April 2016. More specifically, staff are trained in the use of objective assessment at interview which avoids unconscious bias. In addition, all managers receive documentary guidance for shortlisting and interviewing processes for every post advertised. The Recruitment Team are available to offer any additional advice regarding the recruitment process. Managers are encouraged to share recruitment best practices at the training sessions provided and an opportunity is given for this to take place. This also serves as a good opportunity for the trainer to clarify any queries around the recruitment process and again to reiterate best practice. The Trust values the importance of equality and diversity in recruitment at every level of the organisation and is committed to ensuring that fair and consistent processes are followed, both internally and also by any collaborating recruitment agencies. The Trust can confirm that all recruitment agencies working with or on behalf of the Trust have Equality and Diversity Policies in place and apply them as part of their recruitment processes. Where acting up opportunities occur staff are selected by an open recruitment process; if successful they take up the acting opportunity on a fixed term basis. Additionally, in the course of general day-to-day working activities, all staff are able to learn from their peers, mentors and managers to increase both their skills and knowledge. As a University Hospital Trust this should be encouraged thus enabling staff to reach their full potential and to prepare for future opportunities. All staff are able to ask appropriate questions with a view to continued learning. Over time, some staff may have gained more experience that other staff, albeit all staff are able to ask questions, peruse acting up opportunities as they arise and in discussion with their line manager produce an individual learning and development plan during appraisal and access appropriate and relevant study leave. The table below demonstrates recruitment statistics for the period 1 April 2015 to 31 March 2016 for all NCUH posts advertised on NHS Jobs. Enquiries Applicants Shortlisted Appointed Declined Offer Withdrawn A White - British 4074 4296 995 183 1 1 B White - Irish 19 19 4 1 C White - Any other White background 202 214 32 5 CB White Scottish 1 1 1 1 Page 5 of 18
E Mixed - White & Black African 2 2 F Mixed - White & Asian 15 16 5 1 G Mixed - Any other mixed background 19 21 4 H Asian or Asian British - Indian 119 120 16 1 J Asian or Asian British - Pakistani 53 58 14 1 K Asian or Asian British - Bangladeshi 13 14 2 L Asian or Asian British - Any other Asian 80 83 16 1 background M Black or Black British - Caribbean 5 5 1 N Black or Black British - African 165 170 34 1 P Black or Black British - Any other Black 10 10 2 background R Chinese 10 11 5 S Any Other Ethnic Group 39 39 6 Unspecified 2 2 1 17 Z Not Stated 83 85 18 5 Grand Total 4911 5166 1156 217 1 1 10.63% of applications were received from people from a BME background. This percentage is significantly higher than the BME population reported in the 2011 census for Cumbria of 1.5%. A similar number of applicants from a BME background were shortlisted for posts, i.e. 10.73%. The table below demonstrates the numbers of staff by profession and department, comparing those who have been shortlisted to those who were appointed. 120 100 80 60 40 20 0 Nursing & Midwifery Estates Healthcare Scientists Admin & Clerical Add Clinical Services Add Prof Nursing & Midwifery Medical and Dental Admin & Clerical Nursing & Midwifery Medical and Dental Allied Health Admin & Clerical Add Clinical Services Estates Admin & Clerical Nursing & Midwifery Medical and Dental Admin & Clerical Add Clinical Services Add Prof Nursing & Midwifery Estates Allied Health Admin & Clerical Add Clinical Services Add Prof Nursing & Midwifery Estates Allied Health Admin & Clerical Add Clinical Services Add Prof Bank staff Clinical Support Corporate Estates Medicines Paediatric Surgery 2015-2016 Series1 2015-2016 Bank workers Add Prof 2 Add Clinical Services 97 Admin & Clerical 22 Allied Health Professional 2 Estates 20 Nursing & Midwifery 36 Clinical Support Add Prof 6 Add Clinical Services 15 Admin & Clerical 13 Page 6 of 18
Allied Health Professional 2 Estates 20 Nursing & Midwifery 36 Corporate Add Prof 1 Add Clinical Services 1 Admin & Clerical 47 Medical and Dental 3 Nursing & Midwifery 3 Estates Admin & Clerical 5 Estates 21 Medicines Add Clinical Services 60 Admin & Clerical 7 Allied Health Professional 20 Medical and Dental 15 Nursing & Midwifery 42 Paediatric Admin & Clerical 2 Medical and Dental 4 Nursing & Midwifery 1 Surgery Add Prof 3 Add Clinical Services 27 Admin & Clerical 20 Healthcare Scientists 1 Estates 11 Nursing & Midwifery 36 The EDSG agreed that there is no immediate analysis to be undertaken against this indicator, however this will be reviewed once 2016/17 data is available. Page 7 of 18
INDICATOR 3 Relative likelihood of BME staff entering the formal disciplinary process, compared to that of White staff entering the formal disciplinary process, as measured by entry into a formal disciplinary investigation. For this indicator, the Trust will report on a three year basis, to compare data from previous years and to highlight any trends. The table below demonstrates the total number of Trust employees, split by ethnicity, for each of the years used for the comparison. These figures are required when calculating the relative likelihood of entry into the disciplinary process, as detailed below: Year Headcount* White BME 2013/14 4, 143 3, 914 211 2014/15 4, 246 4, 024 190 2015/16 3, 879 3, 695 184 *The headcount figure is not inclusive of the employees for whom we have no recorded ethnic background. In the year 2015/16, 0.79% of employees had an ethnicity recorded as unspecified. NUMBER OF EMPLOYEES ENTERING INTO A FORMAL DISCIPLINARY INVESTIGATION BY ETHNICITY 2013/14 2014/15 2015/16 White 22 White 35 White 38 BME 4 BME - 0 BME - 2 TOTAL: 26 TOTAL: 35 TOTAL: 40 In 2013/14 a total of 26 employees entered into the Trust s formal Disciplinary investigation process. Of these, 22 were of White origin and 4 were of BME origin. This data indicates that the likelihood of a white staff member entering the formal disciplinary investigation process is 1:177.9 and that the likelihood of a BME staff member entering the formal disciplinary process is 1:52.75. Therefore, the relative likelihood of BME staff entering the formal disciplinary process compared to white staff is more than three times greater than that of a white employee. In 2014/15 a total of 35 employees entered into the Trust s formal Disciplinary investigation process. Of these, 35 were of White origin and 0 were of BME origin. This data indicates that the likelihood of a white staff member entering the formal disciplinary process is 1:114.97 and that the likelihood of a BME staff member entering the formal disciplinary process was 0. In 2015/16 a total of 40 employees entered into the Trust s formal Disciplinary investigation process. Of these, 38 were of White origin and 2 were of BME origin. Page 8 of 18
This data indicates that the likelihood of white staff member entering the formal disciplinary investigation process was 1:97.24 and that the likelihood of a BME staff member entering the formal disciplinary process is 1:92. Therefore, BME staff were less likely of entering the formal disciplinary process compared to white staff. Over the last two years, it has been demonstrated that BME employees have been less likely to enter into a formal disciplinary investigation process. The Trust therefore does not need to take any immediate action. The Trust Disciplinary Policy does not discriminate on any grounds and will continue to be applied in a fair and consistent way. WRES states that: the importance of listening to BME staff (and staff sides) about their experiences to better understand the data. For the past three years Trust data shows very low numbers of BME employees entering into the disciplinary process. The Trust considers that it is not currently a priority to establish a formal system to gather feedback. WRES also states that: organisations may wish to consider whether (and if so, why) there are significant differences between the ethnicity of staff entering the disciplinary process and those receiving sanctions. It is proposed that further analysis is undertaken on this during 2016/17. Page 9 of 18
INDICATOR 4 Relative likelihood of BME staff accessing non-mandatory training and CPD as compared to White staff The Trust encourages staff at all levels to undertake a degree of personal development, as outlined in the annual staff Appraisal document. All staff who wish to take study leave are required to complete a study leave application form, as per the Study Leave Policy. Any study leave requests received by the Learning and Development Team are recorded and applications are monitored on a rolling basis to ensure that the process is fair and accessible to all. The Trust s Head of Learning & Development works and meets regularly with the Education Manager for Cumbria Partnership NHS Foundation Trust and also with the Programme Lead for the Cumbria Learning and Improvement Collaborative (CLIC). The Trust is also part of the North West Learning Group and Health Education England North West Group (HEENW) and attending representatives use meetings as an opportunity to learn from and share best practice with other NHS organisations. The table below indicates the number of Trust employees who have applied for and taken study leave in 2015/16. Of 934 study leave applications, 183 of these were from BME employees and 751 were from White employees. No of study leave Ethnicity applications approved in 2015/16 White - British 709 White - Any other White background 39 White Scottish 2 White Mixed 1 Mixed - Any other mixed background 7 Asian or Asian British - Indian 85 Asian or Asian British - Pakistani 21 Asian or Asian British - Any other Asian background 5 Asian Sinhalese 3 Asian Unspecified 8 Black or Black British - Caribbean 2 Black or Black British - African 7 Chinese 3 Any Other Ethnic Group 3 Other Specified 2 Undefined 31 Not Stated 6 TOTAL 934 WRES states that: For the Indicator 4 that compares the relative likelihood of BME staff accessing non mandatory training and CPD compared to White staff, the responses for White and BME staff need to be as similar as possible to those for the organisation s workforce as a whole. Further analysis on this will be undertaken in 2016/17. Page 10 of 18
INDICATOR 5 Percentage of staff experiencing harassment, bullying or abuse from patients, relatives or the public in last 12 months Response Rates In 2013, 800 surveys were distributed, 472 were returned, 19 of which were completed (4.03%) by BME employees. In 2014, 795 surveys were distributed, 465 were returned, 23 of which were completed (4.95%) by BME employees. In 2015, 850 surveys were distributed of which 823 were eligible, 408 returned, 13 of which were completed (4.18%) by BME employees. The table below displays the percentage of staff experiencing harassment, bullying or abuse from patients, relatives or the public in last 12 months, by ethnicity, as recorded in the annual Staff Survey results. 2015 2014 2013 White 28% 28% 29% BME 18% 22% 16% The Trust s Governance Department has provided a breakdown of the number of reports of staff who have experienced physical assault, threatening behaviour and verbal assault (including racial) for the years 2013-2015. 2015 2014 2013 Physical Assault Of Staff 88 131 82 Threatening Behaviour Towards Staff 30 45 42 Verbal Assault Of Staff (Inc 35 38 63 Racial) Grand Total 153 214 187 The results of the Staff Survey show that the Trust has decreased since 2014 in the percentage of BME staff experiencing harassment, bullying or abuse from patients, relatives or the public in last 12 months. This is reflected in the total number of reports made by staff to ULLYSES which shows a decrease from 214 reported cases in 2014 to 153 reported cases in 2015 (although the data from Ulysses is not broken down by ethnicity). Page 11 of 18
Comparing data with comparators in similar types of organisations Cumbria Partnership NHS Foundation Trust plus average (median) rates for other Acute Trusts in England Cumbria Partnership NHS Foundation Trust provides 60 health services across Cumbria and is the neighbouring NHS Trust. The table below indicates the percentage of staff experiencing harassment, bullying or abuse from patients, relatives or the public in last 12 months, as per annual Staff Survey results 2015 for Cumbria Partnership NHS Foundation Trust. Cumbria Partnership has had fewer than 11 responses from BME for Key Finding 25 therefore the result had been replaced with a dash to preserve anonymity of staff. The results show that the percentage of White staff experiencing harassment, bullying or abuse from patients, relatives or the public in the last 12 months is slightly less than Cumbria Partnership. The percentage of BME staff experiencing harassment at NCUH, bullying or abuse from patients, relatives or the public in the last 12 months is lower than the average Acute Trust result nationally. Analysis of data by departments Clinical Support & Cancer Services NCUH Results 2015 Corporate Services Estates & Facilities Cumbria Partnership Results 2015 White 28% 30% 28% BME 18% - 28% Medicine National Average (median) of Acute Trusts Paediatrics BU 15 5 11 47 27 33 Surgery Nearly half of the staff in the Medicine BU who returned the annual staff survey has experienced harassment, bullying or abuse from patients, relatives or the public in the last 12 months. Surgery and Paediatrics also had a high percentage of staff experiencing harassment, bullying or abuse from patients, relatives or the public at 33% and 27%. The lowest percentage of staff to experience this was corporate services at only 5%. It is not possible to break these statistics down by ethnicity, due to the response rates received. WRES states the importance of: Listening to BME staff in order to better understand the data. The EDSG considered that there is sufficient data accessible from the Trust Staff Survey results. Page 12 of 18
INDICATOR 6 Percentage of staff experiencing harassment, bullying or abuse from staff in last 12 months The table below indicates the percentage of staff experiencing harassment, bullying or abuse from staff in last 12 months, as recorded in the annual Staff Survey results 2015. 2015 2014 2013 White 27% 23% 22% BME 23% 17% 37% The table below shows the number of dignity at work complaints made in the Trust for these periods. 2015 2014 2013 Strategic 0 0 1 dept Surgery 2 3 4 Clinical 0 3 0 Support and Cancer services Medicine 1 4 0 Corporate 2 0 0 Estates & 0 0 0 Facilities Child Health 0 0 0 Total 5 10 5 number of complaints White 5 8 5 BME 0 2 0 The percentage of BME staff experiencing discrimination at work from manager/team leader or other colleagues has increased almost 5 times since 2014 rising from 5% of BME staff to 23%. The number of dignity at work complaints shows an increase in the number of complaints raised in 2014 compared to 2013 and then a decrease in 2015 compared to 2014. This trend is a different pattern to the percentage of staff experiencing harassment, bullying or abuse from staff in last 12 months as there is a decrease in 2014 compared to 2013 and an increase in 2015 compared to 2014 s results. Page 13 of 18
Comparing data with comparators in similar types of organisations Cumbria Partnership NHS Foundation Trust (neighbouring Trust) plus the average (median) for other Acute Trusts in England The table below indicates the percentage of staff experiencing harassment, bullying or abuse from staff in last 12 months as per annual Staff Survey results 2015; for Cumbria Partnership NHS Foundation Trust and the national average for Acute Trusts. NCUH Results 2015 Cumbria Average (median) Partnership acute trust in 2015 Results 2015 White 27% 20% 25% BME 23% - 28% TOTAL 50 20 53 Cumbria Partnership has had fewer than 11 responses from BME for Key Finding 26 therefore the result has been replaced with a dash to preserve anonymity of staff. The results show that a higher percentage of white staff at NCUH in comparison to Cumbria Partnership have experienced harassment, bullying or abuse from staff in the last 12 months. The result also show that fewer BME staff at the Trust experience harassment, bullying or abuse from staff in last 12 months in comparison to the acute trust average. Analysis of data by departments Clinical Support & Cancer Services Corporate Services Estates & Facilities Medicine Paediatrics BU 23 19 15 30 9 38 Surgery The results show that the Surgery Business Unit had the highest percentage of staff experiencing harassment, bullying or abuse from staff in last 12 months which is reflected in the number of dignity at work claims - with 2 out of 5 being from Surgery in 2015. Only 1 dignity at work claim was made from the Medicine BU however 30% of staff in Medicine have experienced harassment, bullying or abuse from staff. It is not possible to break these statistics down by ethnicity, due to the response rates received. WRES states the importance of: Listening to BME staff in order to better understand the data. The EDSG considered that there is sufficient data accessible from the Trust Staff Survey results. Page 14 of 18
INDICATOR 7 Percentage believing that trust provides equal opportunities for career progression or promotion The table below indicates the percentage of staff believing that the Trust provides equal opportunities for career progression or promotion. 2015 2014 2013 White 93% 88% 84% BME - 100% 76% The Trust ranked in the best 20% of Acute Trusts results for the percentage of staff believing that the organisation provides equal opportunities for career progression or promotion and is a significant increase in comparison to 2014 s results. Comparing data with comparators in similar types of organisations Cumbria Partnership (neighbouring Trist) and against average (median) of other Acute Trusts in England Percentage believing that trust provides equal opportunities for career progression or promotion NCUH Results 2015 Cumbria Average (median) Partnership acute trust 2015 Results 2015 White 93% 92% 89% BME - - 75% NCUH and Cumbria Partnership have had fewer than 11 responses from BME for Key Finding 21 therefore the result has been replaced with a dash to preserve anonymity of staff. The percentage of white staff believing the organisation provided equal opportunities for career progression or promotion for both NCUH and Cumbria Partnership are similar with only a 1% difference. Analysis of data by departments Clinical Support & Cancer Services Corporate Services Estates & Facilities Medicine Paediatrics BU 96 94 80 95-88 Surgery Page 15 of 18
All the results from the business units are above 80% indicating that a high proportion of staff surveyed believe that the Trust provides equal opportunities for career progression or promotion. WRES states the importance of: Listening to BME staff in order to better understand the data. The EDSG considered that there is sufficient data accessible from the Trust Staff Survey results. In addition, equal opportunities and equality is covered during recruitment and selection and at induction. Page 16 of 18
INDICATOR 8 In the last 12 months have you personally experienced discrimination at work from any of the following? b) Manager/team leader or other colleagues The table below indicates the percentage of staff believing that they have personally experienced discrimination at work from managers, team leaders and/or colleagues. 2015 2014 White 4 8 BME 23 5 TOTAL 27 13 In 2013 the overall percentage reply to this question was 7%. A breakdown for White and BME staff is not available for this part of the question. The percentage of BME staff experiencing discrimination at work from manager/team leader or other colleagues has increased almost 5 times since 2014. However, no BME staff made a dignity at work complaint in 2015. The total number of dignity at work complaints halved in 2015 compared to 2014. EDSG are asked to consider if the Trust should commission further publicity/communications regarding the Dignity At Work Policy and support available with this. (NB the results may indicate that issues felt/experienced by BME staff are resolved internally) Comparing data with comparators in similar types of organisations Cumbria Partnership (neighbouring Trust) and against average (median) of other Acute Trusts in England In the last 12 months have you personally experienced discrimination at work from Manager/team leader or other colleagues? (%) NCUH Results 2015 Cumbria Partnership Results 2015 National (median) Trust 2015 White 4 7 6 BME 23-13 Average Acute Cumbria Partnership has had fewer than 11 responses from BME for Question 17b therefore the result has been replaced with a dash to preserve anonymity of staff. The percentage of staff at NCUH experiencing discrimination at work from manager/team leader or other colleagues (23%) is higher than the average acute trust result of only 13%. The EDSG agreed that outcomes against this indicator required further analysis and this is included in the Trust s 2016/17 Equality Objectives. Page 17 of 18
INDICATOR 9 Boards are expected to be broadly representative of the population they serve The data below indicates the ethnic and cultural make-up of our local population, as per the 2011 Census Information: On Census Day 2011: 96.5% identified themselves as White: British 2% identified themselves as White: Other; O.5% identified themselves as Mixed / Multiple Ethnic Group 0.8% identified themselves as Asian / Asian British (0.8%); 0.1% identified themselves as Black / African / Caribbean / Black British and 0.1% identified themselves as Other Ethnic Group Allerdale Barrow Carlisle Copeland Eden Population 96,422 69,087 107,524 70,603 52,56 4 South Lakes 103,65 8 Cumbria England & Wales 499,858 56,1M % BME 1.1 1.6 1.9 1.5 1.1 1.6 1.5 14.0 % White British % White Other 97.6 97.1 95.0 97.3 97.0 05.6 96.5 80.5 1.3 1.3 3.1 1.2 1.9 2.8 2.0 5.5 The Trust Board is made up of a Chairperson, 6 Executive Directors and 4 Non- Executive Directors. The ethnicity of the Board is detailed in the table below: 2016 White 11 BME 0 WRES states that: Boards are expected to be broadly representative of the population they serve. The percentage of BME citizens in the local community is just 1.5%. There are no members of the Trust Board from a BME background. EDSG considered that there is no significant action to follow up, bearing in mind the low percentage of BME citizens in the local population. Page 18 of 18