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Report 6b of the 25 November 2010 meeting of the MPA Full Authority, outlines the MPS response to Race and Faith Inquiry Report which was presented to the Mayor of London on the 7 July 2010.

Warning: This is archived material and may be out of date. The Metropolitan Police Authority has been replaced by the Mayor's Office for Policing and Crime (MOPC).

See the MOPC website for further information.

Race and Faith Inquiry - formal response by the MPS

Report: 6b
Date: 25 November 2010
By: Director Human Resources on behalf of the Commissioner

Summary

This report outlines the MPS response to Race and Faith Inquiry Report which was presented to the Mayor of London on the 7 July 2010.

A. Recommendations

That Members are asked to note progress made in response to the MPA Race and Faith Scrutiny.

B. Supporting information

1. This report sets out MPS progress towards the issues raised within the MPA Race and Faith Scrutiny. The Scrutiny was the last in a number of reports and reviews each of which have attempted to make the MPS better at delivery of services to the people of London. Many of these have had significant impact (for Instance the MacPherson Inquiry into the death of Stephen Lawrence) but actions to address internal issues of diversity and Race have taken longer to bring visible results.

2. On becoming Chair of the MPA in October 2008, Mayor Boris Johnson announced an independent panel to identify practical positive measures to address concerns expressed about the MPS approach to race and faith. He appointed Cindy Butts as Chair of the Inquiry panel, supported by Anthony Julius and Margret Blankson. The Panel conducted an intensive evidence gathering exercise in the spring of 2009 and retired to consider its findings during the summer. During this period the MPS continued to develop and review its existing Diversity and Equality Strategy, during which the subsequent research and analysis helped develop a draft action plan. Since that time their have been significantly improvements. The Race and Faith Inquiry Report was published and presented to the Mayor of London on 7 July 2010.

3. The enquiry process created considerable energy and focus on key issues for many of our staff from BME backgrounds and those from a variety of faiths. Whilst the impact of the issues that this process raised may have been most strongly felt by members of minority communities they reflected a number of issues which all of our staff can relate to. The MPS are committed to learning from this report and have already begun implementation of nearly all of the recommendations. The process of the enquiry and the publication of the interim findings challenged ways of working so many of our responses are covered within the Equalities and Diversity Strategy 2009 to 2012; launched in December 2009. Many of the significant changes regarding PDR, Promotion and Selection and staff development have been subject to considerable work over the period since then and are due to be reported to the appropriate MPA committees in the coming months.

4. The report contains 9 Recommendations supported by 42 sub-recommendations. The 4th and 9th Recommendations and the 12 sub-recommendations attached are aimed at the MPA and therefore are not commented on here. Of the other 7 Recommendations and 32 sub-recommendations the MPS has already completed a considerable amount of works in line with the recommendations. In almost every case the sub-recommendation has been delivered or is actively being considered. For instance there are major changes being proposed in training and development (linking organisational learning with work of professional standards and organisational survey data to drive activity at areas of identified concern) new PDR and selection processes, a new leadership development model and the new recruitment model all of which have key issues identified in the report built into them and will be presented over the next few months to relevant MPA sub-committees.

5. We have already seen significant improvements in terms of Race and Diversity outcomes. Since the inquiry BME officers had the highest level of representation amongst regular police recruits for the last ten-years, with BME accounting for 17.2% of new recruits, increasing the BME police officer strength to 9.3% and the BME representation amongst police sergeants stands at an all-time high of 5.3%. The HR community engagement strategy has resulted in focused activity with Bangladeshi, Pakistani, Somali and Turkish-Kurdish communities, with excellent representation from these groups amongst special constables and PCSOs; these roles becoming increasing popular with under-represented communities as a way of experiencing MPS culture and accessing other opportunities. Indeed since the Inquiry, the MPS has recruited its first Somali regular police officers.

6. The MetBPA is working in partnership with Recruitment in delivering a revised programme of community engagement, focusing upon London's Black communities; there is an expectation that the programme will result in higher than normal levels of interest in MPS opportunities from the Black communities. New approaches to recruitment were brought before the Authority in September which will build on these successes. The MPA, staff associations and trade unions provided invaluable contributions towards the equality impact assessment of the new recruitment and training proposal, shaping the final model.

7. Of the recommendations the MPS is delivering or developing action to respond to all of relevant parts. There are two which whilst wishing to respond to the issue the MPS is not in a position to identify a way forward. Recommendation 7 includes removing the right of line managers to ‘Veto’ applications. Whilst we agree line managers may not for no reason block moves the MPS feel it is important that line managers must continue to have a significant input into staff development, be it promotion or lateral development. There are currently robust systems and processes in place to prevent the sole decision of a line manager determining the future of an individual. For example for promotion up to and including Inspector, all applications irrespective of whether supported or not by line managers are considered by a selection panel where they are assessed. This is coupled with an additional appeal process and the fairness at work procedure to provide safeguards for staff.

8. This remainder of this paper provides a brief update on the current position and tries to sign post members to where further specific work will be brought forward in the near future. There is still much work to be developed but below sets out a radical set of changes implemented, new work planned and significant improvements in outcomes to date.

9. Recommendation 1
The culture and values of the Metropolitan Police Service (MPS) must shift to become more recognisable to minority members of staff. This means:

  1. putting in place better governance of Staff Support Associations (SSAs) in order that benefits are maximised;
    Agree - Substantial Action taken includes Funding full time co-ordinator who meets regularly Director of Leadership and Learning, Director HR and SSAs
  2. Continuing to build and develop the relationship between MPS and the Met Black Police Association (MetBPA); Agree - Relations with MetBPA have improved considerably with a number of direct meetings between the executive and the deputy Commissioner and full engagement on all issues.
  3. linking staff survey findings and management action more explicitly and transparently; Agree - The Deputy Commissioner holds Business Group leads to account through both the Diversity Executive and Performance Board
  4. ensuring that the process by which lessons relating to race and faith issues (including employment tribunals) are learnt and applied, is clearly set out and understood.
    Agree - This is an emerging piece of work.

10. Recommendation 2
The senior leadership of the Metropolitan Police Service (MPS) should review their commitment to ensuring that officers and staff are fairly treated. This means:

  1. designating the Deputy Commissioner as the lead for diversity and chair of Diversity Board Agree - Completed December 2009
  2. placing Directorate of Citizen Focus and Diversity (DCFD) under the Deputy Commissioner’s direct command Completed - Actioned December 2009
  3. increasing the resources and expertise available to DCFD; focusing the work of DCFD on supporting Operational Commands Agree - There are now 9 Diversity Advisors in DCFD working directly with Business Groups and OCUs to achieve this.
  4. developing a robust internal inspection model within DCFD which can be applied to any part of the organisation. Its remit should encompass two key functions:
    1. To promote and promulgate best practice
    2. investigate those parts of the organization which give rise to concerns; Agree - The Equality and Diversity Strategy has 4 themes. The new Diversity Executive Board looks at and addresses specifically issues raised by the Director of DCFD.
  5. tasking the Performance Board to oversee corporate performance on diversity targets. Agree - Completed April 2010

11. Recommendation 3
Diversity must more clearly be part of the leadership philosophy of the Metropolitan Police Service (MPS). This means:

  1. evaluating the extent to which the Leadership Academy training improves the way difference is managed; Agree - The Leadership Academy is working directly with DCFD to develop a new model for leadership development and clear performance framework in order that these dynamics can be monitored.
  2. aligning the Leadership Academy more closely with the Directorate of Citizen Focus and Diversity (DCFD); Agree - The Director of Leadership and Learning is involving DCFD at the heart of the project to realign and develop a new training and professional development program which will address these issues.
  3. defining what intrusive supervision means in practice and monitoring its implementation. Agree - Considerable work has been done and continues to be done in the MPS to ensure supervisors and leaders understand what is meant in Intrusive Supervision.

12. Recommendation 4 [MPA Responsible for Implementation]
A more flexible approach to recruitment, to increase diverse representation at senior ranks and develop the entire organisation and its performance, is required. This means:

  1. organising a national symposium, hosted by the MPA, to explore the benefits and practicality of multi-point entry for police officers, removing the requirement to progress through every rank. and
  2. instigating discussions with the Government on the issue of multi-point entry.
  3. investing in streamlining the channel from PCSO to police constable so that suitable candidates can be fast tracked.

13. Recommendation 5
Working practices within the MPS that inhibit confidence in HR policies should be revised. This means:

  1. reviewing the 30+ scheme to ensure it is not blocking progression for officers with less service Completed – the 30+ scheme was replaced in 2010 by a much more rigorously applied scheme (the 30++ scheme).
  2. managing temporary and acting promotions centrally; Agree -Temporary promotions of police officers are now all centrally determined and the number has been reduced from about 85 at the time of the investigation into only 20 for internal posts; action is now being taken to further impact on the number and the risks associated with them.
  3. reviewing vetting policy and practice to ensure it is fair, transparent and properly understood. Agree - The vetting policy and SOPs are currently under review by SCD26.

14. Recommendation 6
Disproportionately high black and minority ethnic (BME) resignation rates must reduce. This means:

  1. analysing the reasons for early resignations;
  2. establishing a more sophisticated use of the Personal Development Review (PDR) system to give early warning of dissatisfaction for individual BME officers, allowing for intervention;
  3. identifying key points on the promotion ladder at which BME officers disproportionately leave, and setting retention targets at these points;
  4. reviewing and improving the exit interview process;
  5. clarifying the respective roles of senior officer and lawyers dealing with employment tribunals (ETs) and grievances; and
  6. designating an Association of Chief Police Officer (ACPO) lead for grievances and ET decisions.

Agree - Considerable action has been taken in this area and has been reported into the MPA Remuneration Committee. Action includes the introduction of new exit interview processes, more analysis of the staff survey, monitoring and addressing key blockages to promotion and selection, and adding greater clarity to the role of senior clients in ET and grievance cases (these roles sitting within the ACPO and Senior Director positions within HR).

15. Recommendation 7
Within the Metropolitan Police Service (MPS), the transparency and fairness of internal promotion processes needs to improve. This means:

  1. setting overall black and minority ethnic (BME) progression targets.
    Whilst the MPS accept the rationale that underpins this recommendation, it is important to stress that this aspect needs a much deeper level of discussion as to how manage the process before it can be fully agreed upon. The new promotion process will provide a more positive experience for staff and our ability to track the eligible pool and monitor and ensure proportionate outcomes.
  2. removing the right of managers to veto staff and officers applying for promotion or transfer to specialist posts; This is dealt with in the body of the report so whilst the MPS does not accept the recommendation as it is written further work is being carried out to ensure relationships between line managers and staff on these important decisions are improved.
  3. making lateral development opportunities more widely available by ensuring specialist units are held accountable for increasing opportunities for minority staff Agree Managed through regular reports through diversity board
  4. developing a strategy and supporting action plan to increase the representation of MPS assessors to include more BME and female staff; and Agree Development in progress
  5. appointing external assessors for promotion processes to the ranks of inspector and above. Agree in principle however this needs to be reviewed in light of the new selection process which is intended to address the same issues.

16. Recommendation 8
Internal processes to improve progression and development of black and minority ethnic (BME) officers and members of police staff need to be strengthened. This means:

  1. ensuring that all supervisors in the Metropolitan Police Service (MPS) recognize that they have responsibility for people development; Agree - A new approach to PDRs, selection and Leadership development is currently being developed.
  2. designing and implementing a well developed and adequately resourced development programme for police staff. Agree - Development programs for Police staff at the point of promotion are interwoven with police officer programs.
  3. integrating phase 2 of Equip to Achieve into the overall Human Resources Strategy and effectively communicating its aims and benefits; Agree - A second cohort of the Equip to Achieve progressed through 2009 and further learning was gained. This led to a considerable increase in the number of candidates from BME backgrounds on the Emerging Leaders high potential scheme however the impact on promotion processes was less clear. The new approach to promotion has taken the learning from this program and is building them into wider processes.
  4. implementing a formal, structured, mentoring scheme explicitly designed to benefit mentees. This means:- Agree - The MPS has extensive coaching and mentoring programs which have been designed by the Talent Management Team of the Leadership Academy. MPS coaches are accredited to European Mentoring & Coaching Council [EMCC] practitioner level. We currently have 74 EMCC qualified coaches and 44 qualified mentors. New approaches to Leadership development will greatly expand capacity of and support to mentors.

18. Recommendation 9 [MPA Responsible for Implementation]
The MPA must reinforce its oversight, scrutiny and direction of MPS diversity strategy and performance and address the challenges which currently exist within the MPA. This means:

  1. strengthening the equality and diversity expertise within the organisation at a sufficiently senior level through the appointment of a Head of Diversity
  2. arranging for the Head of Diversity to sit on the MPA’s Senior Management Team (SMT);
  3. reviewing and making improvements to ensure equalities are integrated throughout ALL of the MPA’s work and in particular its committees and sub committees;
  4. reviewing the focus and terms of reference of the MPA Communities, Equalities and People (CEP) Committee and its sub-committees;
  5. ensuring equalities is adequately resourced in the current restructuring exercise to deliver Met Forward;
  6. communicating more effectively with its partners and stakeholders about its priorities with regard to equality and diversity;
  7. being explicit about its expectations of senior police leaders through the recruitment and promotion process for ACPO officers;
  8. championing the case for change in national structures through the Association of Police Authorities (APA).

Conclusion

19. The report above sets out activity to date. The clear improvements in relationships between Staff Support Associations (including the MetBPA) and the MPS are tangible in day to day working and the public comment made by them. Internal lines of responsibility and command have been made clearer through the new Equalities and Diversity Strategy and the associated performance framework. These have put the MPS in a good position to respond to the new Equalities Act and to lead nationally on the implementation of the Police Equalities Scheme.

20. Since the announcement of the start of the inquiry, DCFD has developed and published the new MPS Diversity and Equality Strategy 2010- 2013. The development of the strategy took account of the emerging issues from the inquiry and these have been reflected within the strategy’s four themes: Fair and Responsive Service, Community Engagement, Workforce and Culture and Governance and Performance. Recommendations from the Inquiry that have not already been delivered are being included, as appropriate, into the delivery plan for the Workforce and Culture Theme of the strategy. We have significantly strengthened the governance arrangements for diversity and equality within the MPS, most notably by establishing the Diversity Executive Board, chaired by the Deputy Commissioner, which is responsible for ensuring the MPS achieves the aims set out in its strategy. The Board is supported by a regular performance report that analyses performance across a range of indicators including monitoring workforce composition and progression of under-represented groups, proportionality in numbers of fairness at work, employment tribunal and discipline, and staff satisfaction issues. This will enable the MPS to monitor the outcomes that are fundamental to the Inquiry’s aims. DCFD is working closely with colleagues in HR on a range of issues that include the delivery of the strategy’s action plan, the Developing Training Programme, other change programmes and the Professionalism Board. DCFD has also established its Diversity Practitioners’ Network that supports practitioners from across the organisation in delivering change, resolving issues and sharing good practice.

21. The Staff Support Associations were asked to directly feedback to the Chair of the MPA any concerns that they have. As there is an open system of dialogue and several minutes of formal meetings there are several routes for issues to be raised and discussed which has led to a much more positive and meaningful relationship.

22. The MPS IAG has recently reported on the recommendations and the MPS has not had time to reflect in detail on their observations to include them in this report. However it is acknowledged that these include some powerful and insightful recommendations that the MPS will be seeking to actively implement.

23. Since the Race and Faith Enquiry was commissioned by the Mayor much changed within the MPS and our relationships with Staff Support Associations has improved considerably. However the MPS is clear that there is much more to do. The Deputy Commissioner will lead on the implementation of changes which will be governed through the MPS Diversity Board reporting progress to the MPA through the Communities, Equalities and People Committee. This report sets out the progress so far to address the issues raised within the report and sign posts where further activity is being planned.

C. Other organisational and community implications

Equality and Diversity Impact

This is covered by the overall focus of this report.

Consideration of MET Forward

The Panel’s report is a key element of the Met People strand of Met Forward.

Financial Implications

All costs associated with the activities set out in this report will be contained within existing HR and Business wide budgets.

Legal Implications

1. As a public authority, the MPA is currently required to take action to tackle discrimination, to prevent harassment, and to promote equality of opportunity in all its functions in relation to race, disability and gender. This duty is a proactive one and, although there is discretion as to how this duty is discharged, it should include a demonstrable strategy and monitoring of the strategy.

2. On 8 April 2010, the Equality Act 2010 received Royal Assent. The Act sets out a general duty requiring those subject to the duty to have regard to the need to:

  • eliminate unlawful discrimination, harassment and victimisation;
  • advance equality of opportunity between different groups; and
  • foster good relations between different groups.

3. Some provisions of the Equality Act come into force on 1 October 2010 but the government proposes to bring the general and specific equality duties into force through regulations in April 2011. Public bodies will have an extra year after the regulations have come into force before having to publish their equality objectives and whether they are being met.

Environmental Implications

There are no environmental implications associated with this report.

Risk Implications

Risk management has been built into the existing HR Risk Register.

D. Background papers

None

E. Contact details

Report author(s): DAC Rod Jarman Director of Learning & Leadership, MPS

For more information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

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