Ukraine - A Warm Scots Future: equality impact assessment

Stage 4: Decision making and monitoring

Identifying and establishing any required mitigating action

Have positive or negative impacts been identified for any of the equality groups?

The strategic aims of the paper intend to promote holistic integration for displaced people from Ukraine. The impacts of this policy position paper are therefore expected to be mostly positive in assisting in the reduction of barriers to integration, and provide a parity of offer to other groups, resulting in a range of potentially direct and indirect positive impacts for the equality groups.

There is one potentially negative impact identified, relating to race relations. That promoting integration is a priority shared by Scottish Government and our local authority delivery partners should help mitigate this risk.

It should be noted that specific policy actions to implement the strategic aims are yet to be developed. As these are developed they will require their own EQIAs to ensure that the potential impacts on people with protected characteristics, including intersectional impacts, are fully considered.

In light of the above, and as supplemented by future, more detailed specific impact assessments to be carried out on particular future policy actions, this EQIA will be subject to further review and revision, including in light of developing evidence and circumstances as the war in Ukraine continues.

Is the policy directly or indirectly discriminatory under the Equality Act 2010^[1]?

The policy position paper and strategic priorities indirectly discriminate in favour of displaced people from Ukraine since they are positioned towards this specific group and not other displaced/ refugee cohorts in Scotland. However, the paper repeatedly references the need for parity of support with other groups, and some of the priorities and policy aims within the paper will likely benefit other refugee cohorts.

If the policy is indirectly discriminatory, how is it justified under the relevant legislation?

The main rationale for a different level of support relates to visa status – the Scottish Government sponsors Ukraine visas under the Homes for Ukraine super sponsor scheme and has specific obligations to super sponsor visa-holders. There are not similar provisions in relation to other visa types.

If not justified, what mitigating action will be undertaken?

N/A

Describing how Equality Impact analysis has shaped the policy making process

This EQIA has examined the three needs of the Public Sector Equality Duty, which require public authorities to, with respect to people with protected characteristics, eliminate discrimination, harassment and victimisation; advance equality of opportunity; and foster good relations between persons who share a protected characteristic and those who do not.

This assessment of the strategic direction of the Warm Scots Future indicates that future policy will have some effect on people across protected characteristics. The benefits of the policy position paper should have a positive effect on displaced people from Ukraine and the communities they settle in.

We have found very little evidence of negative impacts for people with protected characteristics at this time, however we will keep this under review as part of the monitoring of this EQIA and as future policy actions are developed further.

Our consultation process with a wide range of stakeholders, and the co-production of the paper with the Scottish Refugee Council and COSLA has informed the development of the five strategic priorities outlined in the Warm Scots Future paper. Additionally, we have taken on board the views of those with lived experience to ensure that the priorities reflect the needs and support required by displaced people from Ukraine. We have also committed to continue working with these groups to shape the implementation of the policy. This will ensure that the differing needs of displaced people from Ukraine are met, including our approach to consider equality impacts for protected characteristics. The priorities have been presented to the Ukraine Stakeholder Reference Group, which includes representation of members with lived experience, to inform and develop this policy position.

Our consultation process has been supported by service design specialists to ensure that the priorities set out in this paper have been designed collaboratively.

Monitoring and Review

This is a high level, overarching EQIA that should be used as a tool and evidence when implementing future policy actions in line with the strategic direction of Scotland’s response to assisting displaced people from Ukraine. It should be noted that EQIAs will be undertaken separately to understand the impact and assess each of the future policies developed.

Officials will gather more data as it becomes available and use this to continuously assess the impact of future policy outcomes as a result of this paper at regular intervals. This includes drawing on the service design expertise available to us to monitor impacts on people with protected characteristics and factor in their experience to the design of policy and services in future. We recognise the changing situation and continue working with our partners and adapting the response as required.