Effective management of equality and diversity benefits both staff and stakeholders and can also positively impact an organisation’s success.
Table of Contents
Basis of response: An organisation known to the author, as the assessment brief permits in place of the supplied scenario. Thornlow Retail Group Limited operates 240 grocery stores and three distribution centres across the United Kingdom, employing 28,000 people, of whom roughly 82 per cent are hourly paid store colleagues. The author is Regional People Partner for the North West, supporting 34 stores and around 3,900 colleagues. Organisational detail is illustrative and anonymised.
Task 1a: Written account on legal and organisational approaches to equality, diversity and inclusion
AC 1.1 Examine the impact of legislative requirements on public and private organisations with respect to equality, diversity and inclusion
The Equality Act 2010. The Act protects nine characteristics and prohibits direct discrimination, indirect discrimination, harassment, victimisation, discrimination arising from disability, and failure to comply with the duty to make reasonable adjustments. Examining its impact on a private retailer, it operates on two fronts simultaneously that a purely office-based employer does not face.
As an employer, Thornlow must ensure that recruitment, scheduling, promotion and disciplinary decisions are objectively justifiable. Indirect discrimination is the provision most frequently engaged in retail: a requirement to work full weekend availability is applied to everyone, and it disadvantages colleagues with caring responsibilities and those with religious observance obligations, so it must be shown to be a proportionate means of achieving a legitimate aim. Examining the practical effect, this makes scheduling policy a discrimination question, which is not how most store managers understand it.
As a service provider, Thornlow owes duties under Part 3 of the Act to customers, including an anticipatory reasonable adjustment duty. Anticipatory means the organisation must consider in advance what disabled customers will need rather than waiting for a request. Examining the impact, this reaches store layout, aisle width, checkout provision, signage, website accessibility and staff awareness, and the duty is continuing rather than discharged by a single audit.
Public sector comparison. Bodies in the public sector shoulder something private employers do not. Section 149 obliges them to pay due regard, in everything they decide, to three aims: getting rid of discrimination, opening up equality of opportunity, and building good relations between groups. Specific duties sit beneath this, requiring publication of equality information and of objectives the body has set itself. Examining the difference in practice, the public duty is procedural and evidential, requiring documented consideration before decisions, which is why equality impact assessment is embedded in public bodies and largely voluntary in private ones. Thornlow encounters the duty indirectly through public sector customers and landlords, and increasingly through commercial tender requirements that import equivalent expectations.
Reporting requirements. Any employer at or above 250 staff already files gender pay gap figures each year. What the Employment Rights Act 2025 adds is an obligation to set out, alongside those figures, an equality action plan, so the exercise no longer stops at publishing a number. Further expansion is close behind. The government’s consultation response of 25 March 2026, issued with draft legislation, settled the shape of ethnicity and disability pay gap reporting at the same 250 threshold, working on a disabled against non-disabled comparison and requiring at least ten people in a group before any figure must be given. Examining the impact for Thornlow, the duty is not yet in force and reporting is unlikely to be required before 2027, but declaration rates cannot be built quickly, so the practical impact begins now.
ion to all staff and stakeholders Approach one: culture audit. Thornlow conducts a biennial audit combining survey data, focus groups and observation across a store sample. Evaluating this, its strength is that it surfaces the gap between stated policy and lived experience, which policy review alone cannot reach, and it produces evidence a board cannot easily dismiss. Its weaknesses are cost, the difficulty of achieving honest participation where colleagues doubt anonymity, and the risk that findings are received and not acted upon, which does more damage than not asking. Its value is diagnostic rather than promotional: it informs what to promote rather than promoting anything itself. Approach two: role models, champions and internal communication. Thornlow appoints trained inclusion champions in each store and publishes colleague profiles and progression stories through its intranet and staff app. Evaluating this approach, its strength is reach: with 82 per cent of colleagues deskless and working varied shifts, the app is the only channel that reliably reaches everyone, and visible role models measurably affect whether colleagues believe progression is open to them. Its weaknesses are that champions are frequently volunteers without authority or protected time, so the role decays; that communication can substitute for change, presenting a favourable picture while structures remain untouched; and that champions drawn only from affected groups signals that inclusion is t...
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