Equality Policy

Equality Policy

Our contact details

Name: Creating Future Opportunities (CFO)

Address: 1100 Daresbury Park, Daresbury, Warrington, England, WA4 4HS

Phone Number: 01925 423 400

E-mail: CFO-ServiceDesk@justice.gov.uk


The purpose of an equality policy is to provide a statement which acts as a public commitment to promoting equality in line with the Public Sector Equality Duty (Equality Act 2010). The Creating Future Opportunities (CFO) Equality policy will be applicable to both CFO programmes (CFO3 and CFO Activity Hubs); however, each programme will adhere to a separate implementation plan. The CFO Equality policy and implementation plans will be publicly accessible documents on the CFO website and be updated and released annually via the CFO Webpage. The policy and plans will be annually reviewed to ensure equality remains a central aspect throughout the entirety of the CFO programme.

CFO are an agency of His Majesty’s Prison and Probation Service (HMPPS) and therefore the priorities detailed within the HMPPS ‘Advancing Diversity and Inclusion staff policy framework’ are the foundation of the CFO organisation and act as a driving force for employees and project implementation and delivery.

“HMPPS is committed to Diversity and Inclusion for all. We treat our staff with respect and ensure equality of opportunity. We deliver our services fairly and respond to individual needs. We insist on respectful and decent behaviour from staff, prisoners, children, people on probation, and others with whom we work. We do not tolerate discrimination, harassment or bullying and we take prompt and appropriate action whenever we discover them. This is underpinned by our adherence to the Public Sector Equalities Duties as outlined in the Equality Act 2010.”

The HMPPS Diversity and Inclusion staff policy framework is applicable for the staff working within CFO; however, an additional policy is required to ensure equality and diversity ideals are a central aspect within the management of the CFO Prime Providers and their Sub-Contractors. The policy will help to ensure equality and diversity ideals are implemented during project delivery to CFO Participants, as well as promoting the importance of equality within the public sector organisation. The equality policy and implementation plan will largely contribute to providing a quality service to Participants.

For CFO, working with ex-offenders, a group in society generally experiencing multiple disadvantages and not accessing mainstream services, ensuring equality and equal access for all is at the heart of its business.  CFO recognises the need to embed its commitment to diversity in all activities including commissioning and contracting. Each CFO Provider is required to demonstrate how they will support equality and diversity during the programme. The CFO Engagement Lead will be responsible for gathering copies of Equality policies from each prime Provider and ensuring annual updates are completed, published and accessible. The CFO Engagement Lead will champion cross cutting themes throughout the CFO programme.

Equality Statement

As CFO is a public sector organisation it has a duty to.

  • Eliminate discrimination, harassment, and victimisation.
  • Advance equality of opportunity
  • Foster good relations between persons who share a relevant protected characteristic and those who do not share it.

The Public Sector Equality Duty (PSED) is a duty on public bodies and others carrying out public functions. It ensures that public bodies consider the needs of individuals in their day-to-day work – when developing policy, delivering services, and making changes that affect their employees.


The CFO Equality and Diversity policy applies to prime Providers, sub-contractors, and CFO employees. Equality and Diversity ideals are the responsibility of all partners, and each should demonstrate a continued commitment throughout the CFO programme. Participant’s engaging with the CFO3, or Activity Hub programme shall be educated on the importance of equality and diversity and encouraged to display positive behaviour.


CFO strive to adhere to all relevant UK legislation; this policy is derived from the principles within the following documents:

  • The Equality Act 2010
  • Rehabilitation of Offenders Act 1974
  • The Human Rights Act 1998
  • Codes of practice issued by Equality & Human Rights Commission
  • Civil Service Diversity & Inclusion Strategy 2022-2025
  • Home Office: Diversity & Inclusion Strategy 2018-2025
  • HMPPS: Diversity and Inclusion Roadmap 2021-2022 (due to updated 2024)
  • Government Communication Service- Our Equality, Diversity & Inclusion Action Plan (2023-2025)
  • Probation workforce strategy June 2023-2025
  • HMPPS – Advancing Diversity & Inclusion for Staff Policy Framework
  • Gender Recognition Act 2004


Roles & ResponsibilitiesCFO as a commissioner

Equality for CFO Providers will include:

  • The CFO3 contracts include a clause (15.1) stating ‘each prime Provider will comply with the Equality Act (2010)’, Providers will be required to evidence Equality Policies and demonstrate an ongoing commitment to Equality throughout the CFO programme. Providers will also be expected to contribute to the HMPPS CFO Implementation plan to evidence how each aspect will be put into practice (updated annually).
  • It is referenced in CFO3 Schedule G (within the contract) the importance of the Equality Act (2010) and how ‘The Provider shall be expected to deliver services that are sensitive to the specific requirements of each of the above groups (ethnic minorities, older prisoners, women, etc.)’. Prime Providers will be required to evidence how the organisation addresses protected characteristics and strive to ensure equality is implemented throughout project delivery.
  • The CFO Activity Hub ESF specification includes a clause (A2.8) which states Providers must ‘maintain a project specific equality strategy/policy and implementation plan to be reviewed by HMPPS CFO’. Providers are also required to ‘ensure a discrimination complaints procedure is in place as well as ensuring an equality policy is in place for participants and staff. Providers must ensure buildings etc comply with the Equality Act (2010) and support and be involved with equality impact assessments undertaken by the department’.
  • The HMPPS CFO Activity Hub Providers received Cross Cutting Theme Guidance following contract award which stated ‘All CFO Activity Hub Providers will be required to submit an Equality Policy and Implementation Plan to outline their commitment to Equality throughout the duration of the CFO contract. The Equality Policy and Plan will be subject to ongoing reviews and Providers will be required to update the policy/plan on an annual basis.
  • The CFO Engagement Lead will request annual policy updates to reflect any changes/development within the prime providers organisations.
  • Providers shall be expected to evidence how internal staff are trained to understand and implement equality and diversity within working practices and behaviours.
  • Providers will be expected to evidence a commitment to anti-bullying and anti-harassment campaigns for internal staff.
  • Providers will hold central copies of all Sub-Contractors equality policies and produce upon request (Sub-Contractor matrices available).
  • Monthly CFO Provider statistics will monitor how many participants engaged with the programme and whether Providers achieved targets for the specified demographics which reflect protected characteristics (men, women, disabled, age category etc.). Prime Providers are expected to meet monthly CFO targets & the CFO will address any under performance and under-representation of protected characteristics.
  • All Providers shall monitor internal staff characteristics and address under representation of protected characteristics.
  • Providers will provide evidence of how accessibility for participants with disabilities will be considered in the project.
  • Providers are required to evidence how older offenders (50+) are encouraged to take engage with the programme and detail any specialist provision.
  • Providers will evidence how women are encouraged to take part in the programme and how delivery is gender specific (CFO3 only).
  • The equality policy shall be included on all Prime Providers websites and staff, participants and stakeholders shall be encouraged to access.
  • Providers will evidence ways in which delivery assess’ participants needs and can be adapted to the individual (marketing material, learning difficulties, language barriers etc.)
  • Providers will encourage participants to develop a further understanding of equality and diversity ideals and apply learned behaviours within the community.


CFO as an employer – Equality within the workplace for internal CFO staff will include:

  • All employees will be recruited via open and fair competition & disabled applicants will be offered the guaranteed interview scheme.
  • The commitment to the wellbeing of all HMPPS is to ensure that employees are safe and equipped to work in the workplace or other locations. This includes providing reasonable workplace adjustments to help staff remain productive where most needed and where it is possible to do so. Making reasonable adjustments for staff with disabilities is a requirement of the Equality Act 2010. Staff should be consulted, and their needs considered in respect of any reasonable adjustments. Any reasonable adjustments must be kept under review to ensure they continue to be effective or necessary, or to identify whether any further support is needed.
  • Other reasonable adjustments include pregnancy, maternity, adoption leave and menopause. Policies available for further guidance and support for staff and line managers. HMPPS have implemented a workplace passport to allow staff to record all workplace adjustment requirements agreed with the line manager. Sharing and discussing the passport will enable line managers to provide staff with tailored support and appropriate work place adjustments. The passport acts as a formal record of an individuals workplace adjustments; allowing them to move around the organisation, without the need for explaining and applying adjustments each time they move. There should be plans in place to review the adjustments regularly to allow for change in circumstance.
  • The MoJ have created a workplace policy that provides information for employees and managers about menopause and signposts to appropriate support and useful resources. In addition, HMPPS have developed a toolkit to support women going through menopause, with advice and information for individuals, colleagues, and managers.
  • The special leave policy applies to all HMPPS staff and can be take in addition to annual leave. Special leave can be paid or unpaid depending on the circumstance and include bereavement, parental leave, health and safety activities, gender identity, school holidays and trade union activities.
  • Gender reassignment leave can be categorised as either paid leave or sickness absence. It enables employees to take time off or to attend appointments or undertake treatments relating to gender affirmation. All transgender employees can apply for gender reassignment leave. The Transgender Employee Support Tam exist to improve the lives of transgender staff in HMPPS and MoJ.
  • HMPPS collects, monitors, and assesses data on all protected characteristics from staff at the point of recruitment and as personal information is updated by employees. HMPPS uses this to identify disproportionate outcomes and to take action to ensure fairness for all. Collection of this data enable the organisation to.
  • Establish a starting point from which we can monitor progress on diversity and inclusion
  • Make evidence-based decisions about where and how to invest resources to retain talent, increase engagement or remove barriers for underrepresented groups
  • Benchmark the diversity of the organisation against the local community or graduate/apprenticeship applicant pool or other key measures, within and outside of the organisation
  • Make assurances to staff about fairness in recruitment, retention, and progression
  • HMPPS want to improve self-declaration rates for staff to be confident HMPPS are recruiting, developing, and retaining people who collectively represent a diverse population. Staff should feel confident in declaring their protected characteristics, be support and encouraged to do so. The data is confidential, anonymised and cannot be used to identify any individual.
  • HMPPS are committed to addressing disparity of outcomes for all staff. HMPPS seek to improve the collection and scrutiny of the data, as well as gather other sources of evidence, to address disproportionate outcomes and meet the organisational ambition of having truly inclusive workplaces free from discrimination, bullying or harassment.
  • A range of Diversity, Equality and Inclusion learning, and development resources are available through the HMPPS Intranet, MyLearning and CSL. The platforms allow staff to access HMPPS, MOJ and the full Civil Service catalogue. All staff across the agency are recommended to complete these basic level courses that can be built upon to develop and improve knowledge and awareness: Equality and Diversity essentials, Disability awareness, Mental health awareness, LGB&T awareness, and Race awareness.
  • Line managers will ensure staff complete mandatory ‘Civil Service Expectations’ training on Civil Service-Learning portal and training is completed on an annual basis.
  • New employees will be informed of the Advancing Diversity and Inclusion staff policy framework and the ‘diversity and inclusion’ section on the HMPPS Intranet & CFO Equality Policy on their first day and the policy shall be referenced in the employee induction pack. Staff will be encouraged to familiarise themselves with the policies and understand the principles of equality and diversity within the workplace.
  • New and existing staff will be informed of policies applicable to working for HMPPS CFO (flexible work/life balance, grievance procedures, occupational health and safety, pay/pensions/benefits, and counselling support) and shown how to access policies to access more information. This will be referenced in the staff induction and staff information pack.
  • Existing staff members will receive a ‘Staff Information Pack’ once a year which details information & policies relevant to CFO (office information, health & safety, HR & IT information). The equality policy shall be referenced within the ‘staff information pack’ and any relevant updates shall be included.
  • The CFO will actively challenge any concerns regarding bullying, harassment, or victimisation and ensure all concerns develop through the appropriate HR channels. The relevant policy can be found on the intranet for staff to raise a grievance and is also referenced in the staff information pack.
  • Staff will follow the Performance Management process (PM) and Reward and Recognition which was introduced 01/04/22 (https://intranet.noms.gsi.gov.uk/support/hr/performance-management)
  • The Performance Management Process will ensure regular conversations will focus on supporting development, future aspirations, wellbeing, and current performance. The regular conversations also include discussion of development needs. Appropriate interventions are recommended and supported including stretching opportunities to develop colleagues’ talents, supporting them to fulfil potential and aspiration to progress; and targeted support to address dips in performance or more sustained under-performance. Doing these in a procedurally fair way will help support staff wellbeing.  Quarterly reviews will be used to review those identified as being high performing, high potential and those requiring support. They will provide oversight and assurance that: regular conversations are happening; development discussions and interventions are taking place appropriately; and recognition and reward is being applied fairly, inclusively and reviewed against budget. There may also be recommendations for additional awards as appropriate. The Recognition and Reward policy underpins the Performance Management policy and provides the opportunity to recognise exceptional behaviours, outstanding demonstration of the MoJ Values, and of staff contributing in many ways, individually or as a team. This recognition and the value of awards (which can be vouchers, cash awards or other small bonuses) are intended to be unrelated to grade, working pattern or any other protected characteristic, instead reflecting the impact of what has been achieved. The policy aims to recognise staff regularly and more immediately when nominated throughout the financial year.
  • All staff are required to complete the mandatory ‘Annual Civil Service Survey’ which includes questions with an equality and diversity theme, HMPPS will engage with MOJ People Group to analyse the results of the survey specifically for bulling and harassment scores; taking appropriate action to improve the outcomes in 2024 people survey.
  • For further advice or support, staff are able to contact the HMPPS Diversity and Inclusion Team. For specific support networks for individuals with protected characteristics, HMPPS have three networks with further networks available as part of MoJ and the Civil Service-
  • DAWN (Disability, Advocacy, Wellbeing Network) support staff with disabilities and associate member
  • PiPP (Pride in Prison and Probation) support LGBT staff and associate member
  • RISE (Racial Inclusion & Striving for Equality) support Black, Asian and Minority Ethnic staff, and associate members
  • The Equality policy will be promoted to all staff members and prime Providers via a CFO bulletin, annual staff Information Pack and uploading onto the CFO website.
  • All Staff must follow the Civil Service Code of Conduct. Inappropriate behaviour will not be tolerated. All allegations will be treated seriously. Staff must formally report matters of serious inappropriate behaviour and follow the processes as described in the Staff Grievance policy. A grievance is defined as any concern, problem or complaint raised by an individual member of staff in relation to their employment. It does not apply to policies where dismissal is a potential outcome and where there is already a separate appeal procedure.


The CFO Engagement Lead will be responsible for the creation and management of this document and will act as an Equality champion. The final version of the document will be reviewed by the Contract Performance Managers, HR Manager and the Senior Management Team and any improvements or amendments shall be included. An annual review shall be scheduled to make any necessary amendments and policy updates.

The policy and implementation plan shall be disseminated to all internal CFO staff and Prime Providers upon completion and uploaded onto the CFO website.

Latest Review: 13.05.24

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