Equality Impact Assessment


EQUALITY IMPACT ASSESSMENT TEMPLATE

UPDATED FOR 2007/08

EQUALITY IMPACT ASSESSMENT

Name of the policy or function being assessed: Investment of the Tower Hamlets Pension

Fund

Directorate Resources

Date Impact Assessment completed April 2010

Is this a policy or function? Function

Is this a new or existing policy or function? Existing

Service Head / Alan Finch
Signature
Date / April 2010

Once you have filled in this document please send a copy to the Diversity and Equalities Team.

If you have any questions regarding this form please call the Diversity and Equalities Team.

SECTION 1

AIMS AND IMPLEMENTATION OF THE POLICY

Identifying the aims of the policy[1]
Statutory pension scheme for staff employed in local government. Investment of the Fund by law is required primarily to optimize the returns from investment for the benefit of the Fund.
The scheme is administered under Ministerial scrutiny by the Department for Communities, Localities and Culture which is responsible for ensuring that it is compliant with equalities legislation and practice.
The Council administers its local Fund and invests the assets. By law, the Fund much be invested so as to optimise returns for the benefit of the taxpayer.

Rationale behind the policy and its delivery

Statutory pension scheme for staff employed in local government. Appropriate investment of the Fund minimizes the cost of the scheme for taxpayers.
Who is affected by the policy? Who is intended to benefit from it and how?
All employees and Members of the London Borough of Tower Hamlets are entitled to join the scheme. Benefits for members of the scheme are financial – either in the form of a pension or lump sum payments.
Investment of the assets provides an income to the Fund and growth in investments adds to its assets. Any shortfall in income or in the value of assets will ultimately need to be paid for by Council Tax payers in Tower Hamlets. Appropriate investment of the Fund therefore primarily benefits taxpayers.
Promotion of good relations between different communities
The scheme does not explicitly or implicitly promote good relations between communities
(Specifically identify the relevance of the aims of the policy to the equality target groups and the Council’s duty to eliminate unlawful racial discrimination, promote equality of opportunity and good relations between people of different racial groups).
The scheme is open to all employees irrespective of race and is a statutory scheme.
Investment decisions in relation to the Fund are taken on the basis of investment risk and return and focus on particular investment markets in order to optimise returns. The Fund has socially responsible investment policy.
Policy Priorities:
The scheme is part of the benefits package for employees of the London Borough of Tower Hamlets. It probably acts as an aid to recruitment to permanent jobs within the Borough.
The Investment Strategy is established to optimise returns to the Fund for the benefit of taxpayers, while taking account of investment risk.

How the policy is implemented

The scheme is a statutory scheme in terms of its contributions and benefits.
The scheme is invested, by law, to achieve the optimum return on investments for the benefit of the Fund. This means that there is relatively little the authority can do to influence the way in which the Fund is invested to achieve policy objectives of the authority.


SECTION 2

CONSIDERATION OF DATA AND RESEARCH

List all examples of quantitative and qualitative data available that will enable the impact assessment to be undertaken
Investment reports from fund managers, investment advisers and independent analysts.

Equalities profile of users or beneficiaries

The membership of the Fund is employees and Members who have decided to join the scheme – data is available from HR.

An equalities profile of Council Tax payers is not readily available but is likely to be similar to that for the total Tower Hamlets population.

Equalities profile of staff

See above

Evidence of Complaints against the service on grounds of discrimination

None

Barriers
All staff may belong to the scheme and are invited to join when first taking up employment with the authority.

Recent consultation exercises carried out

The Investment Strategy is set by the Pensions Committee on the advice of the Investment Panel. The Investment Panel includes a co-opted trade union representative.

Identify areas where more information may be needed and the action taken to obtain this data.

None

Gaps in information:

Action needed:

SECTION 3

ASSESSMENT OF IMPACT

Race – testing of disproportionate or adverse impact

Identify the effect of the policy on different race groups from information available above.

How is the race target group reflected in the take up of the service?

From the evidence above does the policy affect, or have the potential to affect, racial groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination?

If there is an adverse impact, can it be justified on the grounds of promoting equality of opportunity for one racial group or for another legitimate reason?

Could the policy discriminate, directly or indirectly and if so is it justifiable under legislation?

(Include information on adverse impact between different racial groups)


Gender – testing of disproportionate or adverse impact

Identify the effect of the policy on gender groups from information available above.

See above

How are the gender groups reflected in the take up of the service?

From the evidence above does the policy affect, or have the potential to affect, gender groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination?

If there an adverse impact, can it be justified on the grounds of promoting equality of opportunity for one gender group or for another legitimate reason?

Could the policy discriminate, directly or indirectly and if so is it justifiable under legislation?


Disability – testing of disproportionate or adverse impact

Identify the effect of the policy on the disability strand from information available above.

The scheme contains special provisions for those who need to retire as a result of ill health. Otherwise there is no discrimination in the scheme relating to people with disabilities.

How are disabled people reflected in the take up of the service?

From the evidence above does the policy affect, or have the potential to affect, disability groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination?

If there is an adverse impact, can it be justified on the grounds of promoting equality of opportunity for one group or for another legitimate reason?

Could the policy discriminate, directly or indirectly and if so is it justifiable under legislation?


Age – testing of disproportionate or adverse impact

Identify the effect of the policy on different age groups from information available above.

The terms of the national scheme and local discretions over retirement age have recently been changed to prevent age discrimination.

How are young and old people reflected in the take up of the service?

From the evidence above does the policy affect, or have the potential to affect, age groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination?

If there is an adverse impact, can be justified on the grounds of promoting equality of opportunity for one group or for another legitimate reason?

Could the policy discriminate, directly or indirectly, and if so is it justifiable under legislation?


Lesbian, gay, bisexual and trans-gender – testing of disproportionate or adverse impact

Identify the effect of the policy on lesbian, gay, bisexual and trans-gender (LBGT) groups from information available above.

See above

How are LBGT groups reflected in the take up of the service?

From the evidence above does the policy affect, or have the potential to affect LBGT groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination?

If there is an adverse impact which, can it be justified on the grounds of promoting equality of opportunity for one group or for another legitimate reason?

Could the policy discriminate, directly or indirectly and if so is it justifiable under legislation?


Religion/Belief – testing of disproportionate or adverse impact

Identify the effect of the policy on different religion/belief groups from information available above.

See above

How are the religion/belief groups reflected in the take up of the service?

From the evidence above does the policy affect, or have the potential to affect, religion or belief groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination?

If there is an adverse impact, can it be justified on the grounds of promoting equality of opportunity for one group or for another legitimate reason?

Could the policy discriminate, directly or indirectly, and if so is it justifiable under legislation?


Health Impact – testing of disproportionate or adverse impact

Identify the effect of the policy on physical or mental health of service users and the wider community from any information that is available. (This might include an increased risk to health for some groups in the community, which although not intended, may have still occurred. The impact on health might include: increased mental stress, greater risk of accident or injury, reduced opportunities to have a quality diet, reduced opportunity for physical exercise, or greater incidence of diseases such as heart disease and diabetes).

The scheme contains special provisions for those who need to retire as a result of ill health. Otherwise there is no discrimination in the scheme relating to people with disabilities.

From the evidence above does the policy affect, or have the potential to affect the health of groups differently? If so, which groups and how does the impact occur?

Additional groups which may experience a disproportionate or adverse impact

Identify if there are groups, other than those already considered, that may be adversely affected by the policy?

For example those in poverty may be adversely impacted by the policy and it might be useful to consider them as a separate group in the light of the Council’s overall policy objectives.

Not applicable

Additional factors which may influence disproportionate or adverse impact

Management Arrangements

(How is the Service managed, are there any management arrangements which may have a disproportionate impact on the equality target groups?)

Not applicable

What is the custom and practice in the provision or allocation of this service?

(Could these have a disproportionate impact on the equality target groups?)

Not applicable

The Process of Service Delivery
(In particular look at the arrangements for the service being provided).
Not applicable

Operation Times

(When is the service provided; are there seasonal issues; are there barriers to the service based on the time and delivery of the service which may affect the target groups?)

Not applicable

Methods of communication to the public and internally

(What methods do you use to communicate this service? Include review and assessment of methods, media, translations, interpretation etc. bearing in mind the extent to which these media forms are accessible to all sections of the community)

Externally

Annual report sent to every member and available online

Internally

Annual report sent to every member and available online

Awareness of Service by Local People

The scheme is not accessible by local people unless employed by the Council.

Evidence of disproportionate or adverse impact

(Is there any evidence or view that suggests that different equality, or other, target groups in the community have either a disproportionately high or low take up/impact of/from this service/function?)

No

If yes, what and why (State below)

SECTION 4

MEASURES TO MITIGATE DISPROPORTIONATE OR ADVERSE IMPACT

Specify measures that can be taken to remove or minimise the disproportionate impact or adverse effect identified at the end of Section 3. If none were identified in Section 3, identify how disproportionate impact or adverse effect could be avoided in the future. (Consider measures to mitigate any adverse impact and better achieve the promotion of equality of opportunity).

Not applicable

SECTION 5

CONCLUSIONS AND RECOMMENDATIONS

Does the policy comply with equalities legislation, including the Duties to promote equality in relation to race, disability and gender? Take into account your findings from the impact assessment and consultations and explain how the policy was decided upon its intended effects and its benefits.)

Yes

What are the main areas requiring further attention?

None

Summary of recommendations for improvement

How will the results of the Impact Assessment feed into the performance planning process?

Future Monitoring and Consultation

How and when will the policy be monitored?

Suggested consultation for the future

(Identify areas for future consultation and any barriers to participation in consultation with proposals to overcome these).

1

For further information please contact the Corporate Equalities Team on 020 7364 4723

Equality Impact Assessment

SECTION 6 – ACTION PLAN

Recommendation / Key activity / Progress milestones / Officer Responsible / Progress

1

For further information please contact the Corporate Equalities Team on 020 7364 4723

Equality Impact Assessment

1

For further information please contact the Corporate Equalities Team on 020 7364 4723

[1] Please note the term ‘Policy’ is used for simplicity. The broad term can also refer to a function or a service.