International approaches to advance equality: insights from six countries

Section 2: Findings by Country

We now provide an overview of the approaches employed in each country highlighting areas for consideration with a focus on approaches that have had a positive impact on advancing equality.

Belgium

Overview

There are three main pieces of legislation in Belgium that are similar to Scotland's legislative framework in that they apply broadly to organisations providing public services and have a similar threshold for listed authorities. The Gender Mainstreaming Law and the Accessibility Law for Digital Public Services are public sector specific. The Gender Quota Law is applicable to independent public institutions and certain state-owned entities.

Belgium has two agencies that are concerned with advancing equality, one for gender and another that covers the remaining protected characteristics protected from discrimination under the legislation^[5].

Stringent privacy laws govern both the publication and collection of personal data, which is primarily based on sex. The collection of Pay Gap data is only required for organisations with more than 50 employees. Employers are required to discuss their results annually with organised employee representation, which may result in the adoption of an action plan on an optional basis.

Included in the data are employee wages and benefits, as well as sex-segregated information on level of education, job level, training, and type of employment contract.

Social balance statements are also sent to the National Bank, which includes the data in its compilation of national statistics. The creation of gender-neutral job classifications at a sector level and the regular national negotiations of a strategic interprofessional agreement by social partners comprise a substantial portion of the effort to reduce the gender pay disparity (Loi Visant À Lutter Contre L’écart Salarial Entre hommes Et Femmes, 2012). In past reports, a lack of definition and quality control has been mentioned, as the results are primarily reviewed internally and there are no mandated sanctions (Institute for the Equality of Women and Men, 2015).

Impact Assessments are required for policy formulation. The Regulatory Impact Assessment (RIA) contains a so-called ‘Gender Test’ which integrates Gender Impact Assessments into a comprehensive system of impact assessments. This is designed to guarantee that all decision-makers and government employees will take it into account. However, since the ‘Gender Test’ consists of only five open-ended questions its application and impact are limited (European Institute for Gender Equality, 2017).

The Impact Assessment Committee is a component of the Administrative Simplification Agency and functions as the central support entity for all Impact Assessments. Since policymakers are not required to use this service, mandatory quality control is still lacking. Further, our assessment of information gathered during phases 2 & 3 of the review suggests that responses to the ‘Gender Test’ are frequently based on a limited legal perspective and may not adequately address the potential impact of proposed regulations on women and men. To address these issues, revisions are currently being made to strengthen the culture of impact assessments to elicit more meaningful responses and encourage the incorporation of relevant statistics to better comprehend and address the gender-specific implications of proposed regulations. Our research highlights that the acquisition and use of intersectional data are not yet fully integrated into policy. However, we observed that the concept is gaining increasing attention, especially in relation to nuances within gender (Administrative Simplification Agency, 2015).

Key Findings

Impact Assessments are recognised to be a key driver to advance equality and the Belgian authorities have set up systems and organisations to support the process of compiling EQIAs and providing scrutiny. However, our research highlights that the process of EQIA could be enhanced if there was more meaningful and robust approach to quality assurance so that greater emphasis is placed on the impact of the EQIA rather than the process of completing it.

Canada

Overview

The Canadian Human Rights Act and provincial human rights codes in Canada govern equality obligations. These duties collectively recognise protected grounds and prohibit discrimination in a manner similar to the existing frameworks in Scotland.

Canada and Scotland share similarities in addressing pay inequality and reporting on action to advance equality. Like Scotland, Canada's legal framework requires organisations subject to the legislation to report and publish their plans for promoting equality and preventing discrimination. Reporting in Canada is more frequent with information reported annually. Further, in Canada reports should contain information about the demographics of service users. Like Scotland, employee information must be collected for the purposes of monitoring pay equity and publishing information about workforce diversity.

While the role of the Canadian Human Rights Commission is comparable to that of the Equality & Human Rights Commission (EHRC) and Scottish Human Rights Commission (SHRC) in Scotland, the Canadian Commission has a commissioner whose primary responsibility is to promote pay equity with a focus on pay gap reporting.

The Canadian approach to reporting on pay gaps has had an impact on numerous aspects of the labour force. One reported impact is on the job satisfaction of professionals from global majority ethnicities. Our literature review suggested that members of racial minority groups are more attentive to pay differences than Caucasians. This attentiveness has a direct impact on their career satisfaction. In a study of Canadian managerial and professional employees, it was found that career satisfaction increased to a greater extent for members of minority groups than for white respondents with every increase in income (Buttner & Lowe, 2017). This suggests that positive perceptions of pay equity can have a significant impact on career satisfaction and employee engagement for Black and Minority Ethnic workers. This finding suggests that it would be helpful for organisations subject to pay gap reporting duties to improve approaches to data collection, analysis, and reporting of race pay gap data.

Organisations subject to pay gap reporting duties should act to improve the collection and analysis of race pay gap data.

In summary, the approach to pay gap reporting in Canada has had an impact on various aspects of the workforce, including career satisfaction, pay level satisfaction, equal pay for work of equal value, and to an extent, addressing social issues. These findings underline the importance of ensuring fairness and equity in pay structures to enhance employee satisfaction, promote social justice, and provide an evidence base to expand the scope of the pay gap report beyond the protected characteristic of sex.

Impact and Scrutiny of Equality Activity

Annual progress reports are required by the Canadian Human Rights Act (CHRA), the Employment Equity Act (EEA), the Public Sector Equality Act (PSEA), and the Accessible Act Canada (AAC).

The provisions in the CHRA stipulate that the Human Rights Commission must provide an annual report to Parliament in the first quarter of each calendar year. The purpose of this annual report is to provide a summary of the Commission's activities in accordance with Part I and Part II of the CHRA.

In addition, the annual report also provides an opportunity for the Human Rights Commission to meet requirements set out in the EEA that require it to provide an assessment of their effectiveness in implementing the EEA throughout the year and to provide an assessment of the progress made by organisations subject to the EEA.

Accountability to Parliament about progress made, or otherwise, creates opportunities for scrutiny at a national level.

Advancing Equality through Policymaking

Our review of the approach to advancing equality in Canada reveals that the processes of impact evaluation, policymaking, and mainstreaming equality is informed to an extent by intersectional analysis and the active involvement of diverse stakeholders, including representatives from marginalised or underrepresented groups. The CHRA requires consultation with key stakeholders. The Canadian Human Rights Commission is required to hold public consultations for all proposed regulations by the Governor in Council. The Commission must submit a report on the consultation results to the Minister within a reasonable timeframe after the proposed regulation is published in the Canada Gazette (Canada Act, 1982).

Key Findings

Canada has broadly similar approaches to reporting and accountability as in Scotland. Our research suggests that there would be greater impact in addressing persistent inequalities in Canada if there was enhanced understanding at a policymaking level about the intersectionality amongst protected groups so that there was better evidence to inform decision-making. Further, our research findings highlight scope to advance equality if a more robust approach could be adopted in relation to performance management to measure progress both at an individual and organisational level.

New Zealand

Overview

Scotland and New Zealand both have laws requiring public service providers to promote equality and end discrimination. Like Scotland, New Zealand requires organisations subject to equality legislation in the public domain to engage in dialogue and consultation with protected groups and stakeholders in order to fulfil their equality obligations. The Treaty of Waitangi recognises the indigenous Māori people's rights and emphasises cultural diversity and consultation with indigenous communities. When addressing discrimination and equality issues, public entities in both nations must actively involve and solicit input from affected communities.

As a result of the requirements of the legislation in both countries, the public has access to information and reports regarding equality activity; and organisations subject to the legislation are required to collect and use employee information to effectively monitor and address equality and discrimination.

In New Zealand, the Equal Pay Act of 1972 has helped women's pay catch up with that of men. The Employment Relations Act of 2000 promotes workplace equity by supporting collective bargaining and minimum employment standards to protect vulnerable workers from exploitation and discriminatory treatment. The New Zealand Public Health and Disability Act of 2000 has contributed to the reduction of health disparities and the improvement of healthcare for all (Scott & Macaulay, 2012).

From our review of the literature we found that equality duties in New Zealand have improved workplace diversity and discrimination. According to Prenzler, Fleming, and King (2010), affirmative action policies, including those required by the equality duties, have increased the workforce representation of historically underrepresented groups, making New Zealand workplaces more inclusive and diverse. Equality duties are also reported to have reduced discrimination in housing provision.

Impact and Scrutiny of Equality

Regarding the impact and scrutiny of equality activities in New Zealand, the Public Service Act 2020 mandates annual reporting and monitoring of equal employment opportunities and diversity within the public sector. As a result, in accordance with the Act, public sector agencies must submit annual reports to the State Services Commissioner about equality. The agencies are required to report on the representation of various demographic groups in their workforce. The information covers gender^[6], ethnicity, age, disability, and other pertinent characteristics.

The Act also mandates the establishment of specific targets and measures to tackle the underrepresentation of certain groups in public service. The targets aim to promote fair access to opportunities and career growth for all employees. The Public Service Act 2020 promotes the collection and analysis of workforce data by public service agencies to track progress in achieving diversity and inclusion goals (Nolan-Flecha, 2019). The Act also promotes enhancing diversity and inclusion policies in public services to align with the communities they serve.

Our review of legislation, guidance, and literature, highlight that a data-driven approach enables evidence-based decision-making and the identification of disparities for attention.

Agencies must report on their strategies and initiatives for promoting fairness, diversity, and inclusion in public service. This involves outlining measures implemented to enhance workplace representation and promote equality.

Equality and Pay

The Equal Pay Act of 1972 prohibits wage discrimination based on sex and promotes equal pay for equal work, regardless of sex. The Act contains a provision that encourages transparency and accountability through annual reporting. The Act mandates that employers conduct job evaluations to determine the relative value of various positions within their organisations. The evaluation results should be shared with employees to increase the process's transparency. The Act also permits employees to request information regarding the job evaluations and salaries of co-workers in comparable positions. The ‘comparator’ provision permits individuals to compare their pay with that of others, thereby heightening awareness of potential pay disparities. The Equal Pay Act permits employees to file complaints if they believe they are not receiving equal pay for equal work (Parker & Donnelly, 2020).

Monitoring Discrimination

Along with its amendments, the Human Rights Act of 1993 provides a comprehensive framework for reporting and monitoring discrimination and human rights issues. The Act created the Human Rights Commission, which promotes awareness, monitors human rights issues, and handles complaints of discrimination. Individuals can file complaints with the Human Rights Commission to address potential instances of discrimination. The Commission investigates complaints and seeks redress or resolution. The Employment Relations Act (ERA) contains reporting and monitoring mechanisms for equitable employment practices and worker rights, which include reporting for collective bargaining (Zhongming et al., 2017). Parties engaged in collective bargaining are required to report specific information to the Ministry of Business, Innovation, and Employment (MBIE). This reporting promotes transparency in the bargaining process. The Employment Relations Commission was established to resolve employment disputes and enforce the Act. The decisions of the ERA assist monitoring and enforcing equitable employment practices.

The New Zealand Public Health and Disability Act includes reporting requirements for District Health Boards (DHBs) (Came & Tudor, 2017). DHBs are required to submit annual plans and reports to the Minister of Health. The reports provide information on the delivery of health and disability services, with an emphasis on reducing health disparities and guaranteeing equal access to healthcare. The Act establishes entities for monitoring and ensuring the integrity of health and disability services. These mechanisms assure compliance with standards and evaluate the effectiveness of services.

Advancing Equality through Policymaking

In New Zealand, intersectionality is incorporated into impact assessment, policymaking, and mainstreaming. New Zealand's equality laws, including the Public Service Act 2020, Equal Pay Act 1972, Human Rights Act 1993 & Amendments, Employment Relations Act 2000, and New Zealand Public Health and Disability Act 2000, support intersectionality in impact assessment, policy formulation, and mainstreaming. When undertaking impact assessments, policymakers and organisations must consider the potential cumulative effects of policies on different groups, addressing factors such as disability, race, sex, and sexual orientation. The goal of incorporating intersectionality into impact assessments is to identify disparities and inequalities experienced by some communities. Our research suggested that this strategy ensures that policies are tailored to meet the diverse requirements and life experiences of all individuals.

In New Zealand, intersectionality is incorporated into impact assessment, policymaking, and mainstreaming, encouraging the use of an intersectional lens to determine the potential effects of policies and decisions on people with numerous marginalised identities.

Key Findings

The requirements of the New Zealand Public Service Act 2020 have led to a more diverse workforce, and there is evidence that the active recruitment and retention of people from ethnic minority groups and disabled people has made public services more inclusive and representative.

South Africa

Overview

In South Africa the Promotion of Equality and Prevention of Unfair Discrimination Act (PEPUDA) promotes equality in the public and private sectors and the Employment Equity Act (EEA) addresses workplace discrimination and promotes equality. As with the Equality Act (2010) in Great Britain, equality legislation in South Africa seeks to level the playing field for all individuals, guaranteeing equal employment opportunities and fair treatment. In addition, these Acts encourage organisations to actively implement affirmative action measures to rectify historical imbalances and promote inclusiveness. The Affirmative Action provisions in South Africa are comparable to the Positive Action provisions contained in the Equality Act (2010) in that they both seek to promote equal opportunity and address historical disadvantages.

Both the EEA and the SSDs require certain listed authorities to report on progress made to address inequalities. In addition, both countries mandate that listed authorities gather demographic data and publish easily accessible information on equality outcomes. These approaches to reporting on progress and gathering and publishing information create the conditions that encourage stakeholder participation and ensure transparency.

South Africa's equality strategy differs from Scotland's due mainly to historical context. Apartheid and ethnic segregation have had a substantial impact on the South African equality framework. According to Jegede and Shikwambane, (2021), the historical context of apartheid has prompted a targeted and comprehensive strategy in South Africa to address historical injustices and pervasive racial prejudice. Although Scotland doesn’t share an equivalent historical context, legislation and policy in Scotland is designed to address longstanding persistent inequalities such as gender inequality, discrimination based on sexual orientation, and socio-economic disparities. As such, Scottish Government has implemented several policies and initiatives to promote inclusivity and equal opportunities for all individuals, regardless of their background or identity.

Our content analysis of the legislative framework for equality in South Africa and subsequent literature review reveals that South Africa has a well-structured function of progress reporting. This includes a requirement for regular monitoring and evaluation of policies and programmes to ensure accountability and transparency in addressing historical injustices.

There are also efforts to support mainstreaming. South Africa sets national equality goals to combat historical inequalities and promote socioeconomic transformation. The National Development Plan (NDP) defines objectives for a more inclusive society by 2030, with a focus on reducing inequality, enhancing access to essential services, and addressing economic disparities. The objective is to rectify the disparities caused by apartheid. To mainstream this objective, the Employment Equity Act (EEA) defines affirmative action and its duties, and the Promotion of Equality and the Prevention of Unfair Discrimination Act emphasise intersectionality in redress plans by establishing clear regulations on the obligation to consider intersecting identities.

In addition, Section 55 of the South African Employment Equity Act (1998), Chapter 3, on Affirmative Action, directly addresses reporting and scrutiny of the Employment Equity Act. The affirmative action duties embedded in the EEA stipulate that organisations must establish their own annual or biennial goals and disclose their progress to the Commission for Employment Equity using a standardised template. These templates provide the opportunity to collect intersectional data.

Pay Gap Reporting

We were advised in our interviews that the Employment Equity Regulations and the Employment Equity Act (EEA) in South Africa govern pay gap reporting, with the aim of promoting equality and eradicating workplace discrimination. Employers with 50 or more workers are required to submit employment equity reports to the Department of Employment and Labour. Using the templates previously mentioned, these reports must include detailed information about the remuneration received by staff in each staff group and information is also requested by sex and race. Employers are required to provide pay gap information and information about the workforce profile. Further, employers are expected to set numerical targets for the representation of the future workforce. As such the templates act as a workforce planning tool as well as a process of to comply with the reporting requirements of the legislation. As is the case in Sweden, the reports are not made public. However, unlike arrangements in Sweden, in South Africa there are no required steps for internal organisational scrutiny, despite the need to consult staff during the development of the employment equity plan and requirements to share the plan with the workforce once finalised. This may account for the fact that despite the requirements of the EEA mandating pay disparity reporting, compliance with and enforcement of these requirements can vary. The Department of Employment and Labour can conduct audits and investigations to ensure compliance, and failure to comply can result in fines.

The government and equality agencies in South Africa advocate for pay gap transparency and voluntary disclosure, urging employers to proactively address pay disparities and promote greater pay equality. Where there are disproportionate income disparities or unjust discrimination, an employer must take positive steps to reduce such disparities progressively. However, our interviews reveal that the income differential statement is currently a confidential document and that the Employment Conditions Commission is prohibited from disclosing any identifiable information contained within the statement. Beyond these structures, it is the responsibility of organisational leadership to be deliberate in closing the pay gap and reporting on the gender pay gap.

Standardised Equality Reporting Templates

Notable findings in progress reporting include the use of intersectional standards-centred templates for reporting on an organisation's progress towards equality outcomes. Samples of these templates are included in Annex F. The opportunity for intersectional analysis is well developed within these templates; the PEPUDA Act requires intersectional analysis, and the EEA emphasises the duty for organisations to make rectification plans where they have not met their targets. We considered the evidence of the effectiveness of this process in our analysis of interviews and our findings are provided in the thematic analysis.

South Africa has templates that provide the opportunity to collect data to support intersectional analysis.

We found that the templates for reporting on an organisation's progress towards equality outcomes provide a comprehensive framework for assessing intersectional analysis based on protected characteristics and ensuring compliance with the PEPUDA Act and EEA.

Our interviews further support the significance of the nuanced use of data gathered through these templates in driving positive change and fostering a more inclusive environment.

Key Findings

Our findings from our review of literature, combined with feedback from interviews suggested that South Africa's Employment Equity policies have led to positive progress in promoting equal employment opportunities across businesses, although some companies still face challenges and uneven implementation. Further, the clear guidance and standardised templates support data reporting and allow organisations to establish baselines, set goals for workforce diversity, measure progress, and conduct intersectional analysis.

Sweden

Overview

Sweden has a single piece of legislation governing equality. Within the Swedish Discrimination Act there is no specific instrument focused solely on the public sector, rather the Act covers all employers and providers of goods and services. The Act prohibits discrimination based on various grounds, including sex, ethnicity, religion, disability, and sexual orientation.

Sweden introduced a pay equity analysis requirement, focusing on annual compensation mapping, to identify gender-related pay differences and adjust pay within female or male-dominated fields. This analysis is mandatory for organisations with 10 or more employees and must be documented and provided to the Diskriminerings Ombudsmannen (DO) for review upon request (Discrimination Act 2008:567, 2008).

The Swedish Gender Equality Agency provides leadership and direction about gender mainstreaming. As part of a gender mainstreaming strategy, government bills, inquiry committees, and public sector initiatives incorporate gender impact assessments. To support the development of the Gender Impact Assessments there has been investment in appropriate tools and staff training (European Institute for Gender Equality, 2017).

Our interviews highlighted that training and guidance is a key aspect of Sweden’s approach to gender mainstreaming.

There is a mainstreaming programme for government agencies, another for education institutions and universities as well as an overarching programme known as ‘Gender Mainstreaming Plus’. This programme focuses on strategic work, training, learning, and cluster collaboration for those public institutions that are part of these efforts. The six sub-goals of gender equality include equal power distribution, economic equality, gender-equal education, equal distribution of unpaid duties and care, equal health, and the elimination of men's violence against women. The Swedish Equality Agency conducts annual analyses of statistical indicators and reports on progress towards these goals, with Goal 6 focusing on the eradication of violence against women over a ten-year period. It is important to note that Goal 6 not only follows a time frame, but also an action plan.

An Active Approach

Employers must continuously work on active measures, including the investigation and analysis of potential existing discriminatory practices to combat discrimination, advance equal rights, and eradicate obstacles with regard to monitor and evaluate those measures. These measures should address working conditions, payment practices, recruitment, promotion, skill development, and balancing work and family responsibilities. Employers must also implement policies against harassment and promote gender equality through training and development. Employers are required to progress this work in cooperation with employees.

Our research highlights that employers with more than ten workers are required to document their pay surveys and explain how they cooperated with their employees, while those with more than twenty-five employees must document all their work on active measures to promote equal rights and non-discrimination and how the results of the pay difference survey can be improved. If a pay gap is identified, companies must document the measures they have taken to close it, along with their implementation timeline, monthly or annual expenditures, and progress over the past year.

Scrutiny Procedures

Regarding scrutiny procedures, the Equality Ombudsman oversees the implementation of the Equality Act and has the power to impose penalties for noncompliance. Unions lead efforts to resolve disparities in female-dominated occupations by focusing on education, risk, and other variables.

The Swedish Gender Equality Agency focuses on anti-discrimination policies and helps in its area of expertise. It recognises the impact of social factors such as race, ethnicity, and socioeconomic standing on gender equality, with the objective of creating more inclusive and equitable opportunities. In terms of age, sexual orientation, education, and lifetime earnings, intersectionality is examined. According to our interviews, Sweden does not collect data on race or ethnicity, but they do consider data about country of birth - for example information gathered from immigration data or if they were born in Sweden - when calculating lifetime earnings.

Regarding accessibility, there is no specific requirement to publish reports in an accessible format. However, the Swedish Government publishes on its website reports describing how it complies with the requirements of the Act on Accessibility of Digital Public Services.

Key Findings

Sweden's gender mainstreaming efforts focus on reporting, data acquisition, and use of information. The duties that are mentioned in the Swedish Discrimination Act apply to all employers and all sectors and in some instances compel organisations with 10 employees and more to document action on equality. The emphasis on documentation, proactive measures, and internal review ensures compliance. We also note that pay gap reporting includes a focus on gender gaps in sectors where men and women are not equally represented.

The key takeaway is the approach to scrutiny. In Sweden there is no legislative requirement for organisations to publicly report pay gap information. However, employers are accountable to their board and workforce, and where this is a requirement, it seems to drive progress.

Further, reports are required to be shared with the relevant government agency on request. In addition, Swedish Government Ministers take a focused approach to drive progress and have been known to target requirements to advance equality in specific sectors. This is similar in practice to the existing SSDs (Regulation 11) and the proposal to set sector specific equality outcomes contained in the consultation on the effectiveness of the Public Sector Equality Duty in Scotland.

Wales

Overview

Like Scotland, equalities legislation in Wales is mostly reserved. As such, Wales has a set of specific duties with similar aims to the SSDS. The Welsh Duties apply to public authorities and are aimed at advancing equality and preventing discrimination for people with protected characteristics. Additionally, there is a requirement to publish reports in an accessible manner and make considerations regarding how public procurement can advance equality. However, there are some differences between the two countries' reporting responsibilities.

In Wales, specific duties provide increased focus on engagement of groups representative of the needs of people sharing protected characteristics in the development of equality objectives.

Despite following a similar reporting timescale in relation to PSED reporting, listed authorities in Wales are also required to develop an Annual Strategic Plan.

A Strategic Equality Plan must be published and routinely updated, and it must contain a statement outlining the organisation's equality objectives, the steps it has already taken to achieve those goals, and a timetable for achieving those objectives. In addition, it describes how progress towards the objectives is monitored and any other measures taken to comply with the equality duties. This also includes Equality Impact Assessment Reports and information about training and employment data collection. In addition, it includes the Pay and Action Plan, which contains data on pay disparities.

Noting what would appear to be an increased reporting burden for listed authorities in Wales we note that the EHRC in Scotland advocates for opportunities to streamline equality reporting^[7], advising listed authorities to take opportunities to include information about progress towards equality objectives in annual reports, and information about workforce demographics in regular workforce reports.

Within the Welsh Specific Duty there is a requirement to compile and publish information on pay differences. The information that must be collected should be broken down by sex, job, job grade (if applicable), salary, contract type, and working pattern. This information is required to be broken down by relevant protected characteristics, the number of applicants and position changes within the listed authority, training requests and completions, employees involved in grievance procedures, employees subject to disciplinary proceedings, and employees leaving the authority. There is no requirement for these reports to be in a specific format. (The Equality Act 2010 (Statutory Duties) (Wales) Regulations 2011).

The Welsh Specific Duties also require consideration of pay disparities between employees who have or share a protected characteristic when devising equality goals.

A listed body must publish any equality objectives that address gender pay disparities, the measures it has taken or plans to take to achieve those objectives, and an action plan to reduce these disparities.

Scrutiny of the Welsh public sector equality duty has been the subject of discussion and review (Parken, 2019). Our investigations highlight that the Welsh Assembly reports on progress against the Welsh Specific Duties every four years, with scrutiny in relation to compliance with the requirements of the Welsh Specific Duties sitting with the EHRC in Wales. Feedback received through our review of the available literature and our interviews suggests that the current approach leads to confusion on the part of listed authorities.

Equality Impact Assessments

Regarding Impact Assessments, while provisions exist in both Scotland and Wales to assess and review proposed policies and practices, public authorities in Wales are required to publish a report detailing all the steps and information used to conduct the assessment. This includes both the results and the decisions made in response to those results, whereas the Scottish obligation only requires the results to be published.

Both nations are obligated to set and publish Equality Outcomes, or equality objectives. Wales sets equality objectives for each of the protected characteristics. Our interviews revealed that equality objectives vary in quality and frequently lack connections to existing evidence relating to persistent inequalities.

In addition to the PSED and the Welsh Specific Duties, the Well-Being of Future Generations Act is an overarching act that incorporates sustainability objectives, inspired by the United Nations Sustainable Development Goals, with equality as one of its objectives. This Act has its own reporting schedule that overlaps with aspects of the equality legislation in Wales. Our review of the literature and findings from interviews suggested that there would be benefit from increased co-ordination with a focus on reducing the bureaucratic burden of compliance reporting as required by the PSED and the Well-Being of Future Generations Act. Recommendations included cross-referencing in policies and the alignment of reporting responsibilities (Parken, 2019). Recent discussions have also included the possibility of delineating national equality priorities that can be linked to the Well-Being of Future Generations Act's overall objectives (Davies, 2019).

Finally, in terms of intersectionality, Wales is working to increase awareness and implement an intersectional approach to policymaking.

Key Findings

Our research highlights, that like Scotland, there is a focus in Wales to explore how it can align reporting requirements to reduce the burden on authorities so that there is an increased focus on addressing persistent inequalities. Further, our review of the literature and feedback from interviews suggested that there is a need to enhance guidance and templates so that there is greater consistency and more opportunities to measure progress, with a focus on information about pay disparities. Further, we understand that the impact of regulators and funders, such as the Higher Education Funding Council for Wales, on equality-related objectives and efforts has been substantial. To improve outcomes, Scotland could benefit from encouraging Non-Departmental Government Bodies with a similar regulatory, funding or scrutiny remit to set sector specific equality outcomes. We note of course that in Scotland the EHRC has worked with the Scottish Funding Council to set equality outcomes for the Scottish tertiary education sector^[8] and this approach also provides a framework to follow.