Equality, Diversity and Inclusion Strategy

CEO introduction

This is a crucial time for organisations to determine their role in society and consider their impact. In recent years we’ve seen social movements bring long-standing issues into sharp focus, and the impact of the global COVID-19 pandemic is likely to have far-reaching consequences on the most vulnerable and marginalised in our society. This ‘wake-up call’ has, quite rightly, put a heightened pressure on businesses and employers to ensure they are fair and inclusive in the way they operate, and the way they look after the people who work for them.

As a public body, the UK regulator of workplace pensions, and as an employer, The Pensions Regulator (TPR) has been on this journey for some time. But we know we have much more to do to ensure workplace pensions work for all savers, and to increase representation within our organisation while building a fair and inclusive culture for our workforce. As an employer, we need to do more, not only to attract diverse talent but to keep people when they join us. We need to really challenge ourselves about why we are not diverse enough in the senior levels of our organisation and ask what we can do as a community to help all our people feel safe and supported at work. We want to influence and drive change across the pensions industry and to do that we need to take an honest look at ourselves as an employer and address those areas where we must do more.

We have clearly set out our commitment to making workplace pensions work for savers in our new Corporate Strategy. With the explosion of the number of people saving for their retirement as a result of automatic enrolment (AE), those savers we protect have become an increasingly diverse group. We have been clear in our Corporate Strategy that we want all savers to get good value for their money, all those that make decisions on behalf of savers to be scrutinised, and to be a bold and effective regulator. Improving diversity and inclusion is fundamental to these goals and when we say we want to put the saver at the heart of all that we do – that means all savers.

Within this context, we have a responsibility to explore issues that may disproportionately impact different groups such as ethnic minorities, women, people from the LGBT+ community, people of all socio-economic status, people with physical and mental health conditions and disabilities, and those who have caring responsibilities. We must understand their needs and, through our regulatory work with others, remove barriers preventing them from participating fully.

Diversity and inclusion is important to good governance and decision-making, and therefore in achieving good outcomes for savers. So far, we have consulted with the industry on the future of trusteeship and how we can raise the standards of governance to protect all savers, and we have established an industry working group to address the lack of diversity and inclusion among pension governing bodies. I greatly look forward to seeing the outcomes from this group.

For many years we have prioritised equality, diversity and inclusion (EDI) initiatives in our workplace and have several well-established diversity network groups. We have maintained a strong balance between males and females across senior roles at TPR but we recognise we still have a long way to go to increase representation more broadly and close unfair pay gaps between certain groups (such as between white colleagues and those from an ethnic minority background or relating to other factors such as sex, disability and sexual orientation).

We have more to do to build trust with all our people, so we can obtain the data about our workforce that we need to develop policies and practices to support all our people effectively. We want every member of our team to know that they work in an organisation of allies and supporters who will speak up about any behaviour that does not reflect our clear commitment to be a fully inclusive organisation that values every person equally.

We have set out a vision of building a workplace pension system that works for everyone. To deliver on this we have identified three strategic aims between now and 2025¹:

To be a fair, diverse and inclusive employer: as an organisation, we must become more diverse and create the right environment for our people to thrive and be their best selves. We will continue to build an inclusive culture in which our increasingly diverse community feels safe, supported and celebrated throughout their career at TPR.
To build a collective understanding of why pensions inequalities occur and, within our regulatory remit, work in partnership with others seeking to reduce them: Recognising the need to lead from the front in effecting change in the pensions landscape we also want to go beyond our public sector equality duty to demonstrate the equality we want to see in the industry. We will therefore contribute to the ongoing development of the evidence base for why pensions inequalities occur, to inform evidence-based policy making and help support industry, fellow regulators and central government to achieve the best outcomes for all workplace savers.
To promote high standards of equality, diversity and inclusion among our regulated community: we will work with and influence the governing bodies that manage workplace schemes, providing positive support and encouragement to help them become more diverse and inclusive in their decision-making.

This strategy sets out the framework we have used to build our action plan for the period 2021 to 2025, as well as providing a foundation for our longer-term ambitions to drive change within our organisation, those we regulate and the wider financial sector.

Charles Counsell, Chief Executive

Context

The pensions industry

This is a complex time for the pensions and wider financial sector. The past decade has seen significant changes to the landscape, for example with the introduction of AE and the consolidation of the defined contribution (DC) market, and we expect further changes in the coming years.

The introduction of AE has seen a dramatic change in the pensions industry. It has meant more people, including more women, more people from ethnic minority backgrounds, more young people, more disabled people, and more people on low incomes, are saving into pension schemes. With more people than ever before saving into a workplace pension, there has never been a more important time for pension schemes to be well-run, with good governance and decision-making at their heart.

The COVID-19 pandemic has transformed many areas of our lives and highlighted and intensified some of the greater inequalities that exist within our society. Responses to the pandemic have also shown the positive impact collaboration can have and the importance of inclusion within organisations and the wider community.

How TPR fits in

TPR is the public body that protects workplace pensions within the UK. We are based in Brighton and Birmingham, with about 900 employees. Our aim is to be a clear, quick and tough regulator that protects and enhances savers’ pension outcomes.

We have embarked on a 15-year Corporate Strategy to make workplace pensions work for savers. This sets out our commitment to enhance and protect all savers’ pensions through delivering on five strategic goals:

savers’ money is secure
savers get good value for their money
decisions made on behalf of savers are in their best interests
the market innovates to meet savers’ needs
TPR is a bold and effective regulator

In setting out to create a workplace pension system that works for everyone through this diversity and inclusion strategy, as well as other aspects of our Corporate Strategy, we are seeking to ensure that:

all savers get good value for their money
decisions made on behalf of savers are in the best interests of all savers
we as a regulator are transforming how we regulate to put all savers at the heart of our work

TPR is a significant employer within the pensions industry and a major local employer in the Brighton area, as well as having teams based in Birmingham. We want to build stronger links within the pensions industry and with our local communities, so we can build diverse talent pools and provide access to careers that may not have historically been considered by members of some communities.

We need to do more to become a truly inclusive organisation. Recent internal research has identified we have work to do to ensure we fully embody inclusive values and behaviours. For example, from looking at our data it is clear we need to prioritise closing the unfair pay gaps that exist for our people, particularly women, and those who are from ethnic minority backgrounds and the LGBT+ community. We must do more to ensure that all our people feel included, listened to and valued for everything they contribute.

We appreciate that this will be a journey over time. This strategy outlines our ambitions for the kind of organisation we want to be, and some initial actions we have identified as steps along the way. It is not, however, exhaustive and we will be refining our approach in the coming months and years as we continue to develop our thinking, learn more and put this into practice.

What do we mean when we talk about equality, diversity and inclusion?

Equality

According to the Equality and Human Rights Commission, “Equality is about ensuring that every individual has an equal opportunity to make the most of their lives and talents. It is also the belief that no one should have poorer life chances because of the way they were born, where they come from, what they believe, or whether they have a disability. Equality recognises that historically certain groups of people with protected characteristics such as race, disability, sex and sexual orientation have experienced discrimination.”

Diversity

We recognise that there can be many ‘forms’ of diversity – at its broadest, diversity can mean any aspect that differentiates groups and individuals from each other. The law (the Equality Act 2010 which, for public sector bodies including TPR, includes the public sector equality duty) specifically protects people with any one or more of nine ‘protected characteristics':

Nine circles showing: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation.

As shown above, the Equality Act 2010 protects ‘sex’ and ‘gender reassignment’, but in this strategy we use the term ‘gender’ in accordance with the meaning defined by the Office for National Statistics and used by UK government bodies². When referring to ‘gender’ we mean:

a social construction relating to behaviours and attributes based on labels of masculinity and femininity; gender identity is a personal, internal perception of oneself and so the gender category someone identifies with may not match the sex they were assigned at birth
where an individual may see themselves as a man, a woman, as having no gender, or as having a non-binary gender – or where people identify as somewhere on a spectrum between man and woman

We acknowledge that diversity goes beyond the protected characteristics and can also include other differences, including those that may not be obvious when first meeting someone, for example socio-economic background, having caring responsibilities, and neurodiversity. We also recognised the increased disadvantages people face where some factors or characteristics intersect, for example sex and race, and the importance of the need to understand people’s experiences in light of this. We also recognise that everyone’s experience is unique and complex. Identities are multifaceted and overlap. For example, the mixture of advantage and disadvantage faced by a white disabled man, or the many forms of disadvantage or discrimination faced by a black trans woman. While the activities in this document initially focus on under-represented groups we have a longer-term ambitious aim to view our activities through an intersectional lens.

Inclusion

By ‘inclusion/inclusivity’ we mean a culture where all individuals are effectively involved, valued and supported, creating an environment where our people can thrive and reach their full potential. An inclusive environment is one which is beneficial to individuals and to organisations, by making sure (among other benefits) that a wide range of perspectives are considered, enabling the best decisions to be made.

We also recognise that equality, diversity and inclusion are all parts of the same whole. For example, having people from different backgrounds working in an organisation might enable an organisation to say that it is ‘diverse’ but if those people are treated less favourably than the majority, or don’t feel able to speak out, then that organisation will not benefit from the full talents and experiences of those people – and indeed are likely to lose them quickly.

TPR aspires to be an organisation that treats people equitably, is diverse and inclusive in its approach and culture, and wants to support the wider pensions industry in the same aims.

Our vision and aims

Our Corporate Strategy sets out that we will put the saver at the heart of all that we do and enhance and protect all savers’ pensions. To do that effectively, we know we need to build a collective understanding of why inequalities occur, influence our regulated community to ensure diversity in decision-making, and lead from the front and become a truly a diverse and inclusive employer so we can drive the change we need to see in the wider industry.

Vision: To build a workplace pensions system that works for everyone

Aims

Our ambitions

Strategic aim 1

To be a fair, diverse and inclusive employer: as an organisation, we must become more diverse and create the right environment for our people to thrive and be their best selves. We will continue to build an inclusive culture in which our increasingly diverse community feels safe, supported and celebrated throughout their career at TPR.

Who we are and what we are already doing

There has been relatively little change to the composition of our workforce in recent years. As at the end of 2020/21 of our c.900-person workforce, data shows:

Age: We have people of all ages working for us. The majority of our workforce (83%) are aged between 30 and 59, with the average age being 43. This is similar to last year where 85% of our workforce was aged between 30 and 59 and the average age was 42.
Disability: 5% of our workforce told us they have a disability. 82% of staff did not declare a disability. This is the same as last year. 7% of our senior leadership team (CEO, Executive Directors, Directors and Heads) declared a disability. This is a decrease of 1% compared to last year where 8% of our senior leadership team declared a disability.
Ethnicity: 7% of our workforce declared they were from a black, Asian or ethnic minority background. This is the same as last year. 77% declared they were of white origin - a decrease of 2% compared to last year. No colleagues from our senior leadership team (CEO, Executive Directors, Directors and Heads) declared they were from a black, Asian or ethnic minority background. This is the same as last year.
Marriage and civil partnership: 50% of the workforce declared themselves as married or in a civil partnership. This is an increase of 6% compared to last year.
Religion or belief: 32% of our workforce declared a religion. This the same as last year. 48% declared they have no religion - an increase of 3% compared to last year.
Sex: We maintain a strong overall and senior leadership balance between men and women. 51% of staff are female and 49% are male, with 57% female representation at senior leadership team level (CEO, Executive Directors, Directors and Heads). The overall balance is the same as last year, however there has been a 7% increase of female representation within the senior leadership team compared to last year (50% female representation) and we are pleased that our female representation is high.
Sexual orientation: 8% of our workforce declared themselves gay, lesbian or bisexual. This is a decrease of 1% compared to last year. No colleagues from our senior leadership team (CEO, Executive Directors, Directors and Heads) declared themselves as gay, lesbian or bisexual. This is the same as last year.
We are unable to report on colleagues whose gender identity differs from the sex assigned at birth due to the small number of staff members who declare themself within this group, however we are committed to monitoring (though not publishing) their pay gaps and representation, and looking to close those pay gaps and increase their representation.

For TPR to become a more diverse and inclusive organisation, we are committed to continuous scrutiny of our culture and practices so we can improve them. We will continue to listen to and learn from our people to understand what we can do better.

Employee networks have been established, each with sponsorship from members of our Executive Committee: The Disability Network, ME (Minority Ethnic) Network, PROUD (LGBT+) Network, Women’s Network, and Time to Change Champions (mental health). Our diversity networks are voluntary, employee-led groups, which provide a forum for individuals to come together from across the organisation to share ideas, raise awareness of challenges and provide support to each other. They have proven to be an important mechanism for providing an employee voice for different groups, offering formal and informal support to colleagues and driving change as well as giving colleagues the opportunity to grow personally and professionally.

We have also established an EDI Committee (a sub-committee of our Executive Committee, co-chaired by two Directors), which is responsible for leading and directing our internal and external diversity and inclusion agenda, providing direction championing inclusion, and taking decisions on diversity and inclusion matters, both within our workforce and in the community we regulate. Members include representatives from a range of roles and levels from the business.

We recognise that the pensions sector (including TPR) has historically attracted a less than diverse talent pool. Despite this, over the past five years, TPR has maintained a strong balance in the number of women at senior leadership levels (57%) and across the organisation (51%). Our gender pay gap action plan has helped decreased the pay gap by 2.4% from 2019 (8.7%), and currently stands at 6.3%.

What more do we need to do?

Despite this encouraging progress, there is, however, much more we can do. The number of women in technological and specialist roles has declined over the past year and we are committed to increasing the number of women working within these teams.

There is still a lot of work to do regarding our pay gaps for people from ethnic minority backgrounds and LGBT+ employees. The bonus gap between white and ethnic minority colleagues for 2019/20 is 23.7%. The bonus gap for LGBO+³ (lesbian, gay, bisexual and other) is 18.5% for the same period. We recognise that this cannot continue and are committed to taking steps to address this. Furthermore, we need to make sure that and making our reporting becomes inclusive of the trans and non-binary community, and we are making efforts to do this.

Analysis of our workforce data shows that TPR has no ethnic minority or openly LGBT+ people at executive or senior leadership levels within the organisation. We are committed to increasing ethnic minority and LGBT+ representation across our executive and senior leadership teams to at least 15% of our senior leadership team within the next two years. We will work hard to make sure TPR is seen as an employer of choice for people currently under-represented in our organisation and that they join feeling confident that they will be supported to thrive as part of our organisation.

Finally, we recognise we have work to do to improve the position of disabled people and those with health conditions who work at TPR. Staff who declare a disability equate to 5% of our workforce, with 7% of those in senior roles, which equates to around three people. We need to increase representation and ensure staff have the support to fully participate within the organisation. We are committed to addressing barriers that exist in achieving this.

How we will do this

We are committed to ensuring our policymaking and decision-making reflects our values and principles. Our ambition is to align our work on diversity and inclusion with key national benchmarks and standards. We are committed to achieving the National Equality Standard and exploring participation in other national equality, diversity and inclusion charters, such as Business in the Community (BITC)’s Race at Work Charter, Stonewall Workplace Champions, Disability Confident Employers’ Scheme, and Mindful Employer Charter.

We want to ensure there is clarity and transparency that will guide our people, including managers, on our intentions, values and behaviours. We will:

set out what an inclusive organisation looks like and embed this into our everyday activities
revise our values and behaviours framework to emphasise the importance of equality,
diversity and inclusion
work with our people so we can be more proactive and flexible in making positive changes
support our people by recruiting for a senior role to work across TPR to help our teams embed our strategy

By making these changes, and showing our commitment to building an inclusive culture, we intend to foster an environment of greater trust and confidence among our people. We need to improve our workforce equality data, so we can better understand our workforce and design effective improvements to our policies, procedures and employee experience. We hope that by increasing trust and confidence and doing more to explain the benefits of high declaration rates (such as the positive impact it can have on targeted interventions and closing pay gaps) we will be able to achieve this.

We want to attract a wide range of people to work for us, and for our new joiners to be clear about and share our commitment to equality, diversity and inclusion. As a result, we will review and enhance our recruitment processes to ensure they don’t include any barriers to accessing and progressing in the organisation. We want to work with our local community and professional bodies to really make a difference in opening career choices for those who would have not traditionally considered the pensions sector as an option.

Objective 1.1

Working together with our people, we will develop an inclusive culture that enables us all to thrive and grow within TPR. We are committed to measuring how our people experience their sense of inclusion within the organisation. We will revise our Values and Behaviours framework to embed equality, diversity and inclusion within our culture to inform our work and how we deliver it. We will work with our people to better tackle inequalities within our workforce. We will provide a forum to continually listen to colleague views, which is supported/ sponsored at our most senior level. We will actively set benchmarks and measure levels of inclusion within TPR with the commitment to take action to ensure a marked improvement by 2025.

Objective 1.2

We will work at a local and national level to increase the diversity of our workforce and push for greater access to careers and opportunities within the pensions industry. In doing so, we will play a leading role in influencing the growth of diverse talent within the sector to ensure future sustainability. We will set challenging workforce targets to increase the diversity of our workforce by 20% across under-represented groups (including black and ethnic minorities, LGBT+ and those with disabilities) by 2025.

Objective 1.3

We will review our internal remuneration and recruitment policies and processes, with a specific focus on gender, ethnicity, LGBT+ and disability pay gaps. We will create proactive action plans to support the development of underrepresented groups to ensure their full participation within the workplace. We will publish an action plan by 2022 setting how we will reduce the pay gaps for under-represented groups.

Strategic aim 2

To build a collective understanding of why pensions inequalities occur and, within our regulatory remit, work in partnership with others seeking to reduce them: Recognising the need to lead from the front in affecting change in the pensions landscape we also want to go beyond our public sector equality duty to demonstrate the equality we want to see in the industry. We will therefore contribute to the ongoing development of the evidence base for why pensions inequalities occur, to inform evidence-based policy making and help support industry, fellow regulators and central government to achieve the best outcomes for all workplace savers.

The introduction of AE has helped many people who would not traditionally have been workplace savers to start saving for retirement. Although there is a long way to go, the profile of savers has become more diverse and expected retirement outcomes for many are improving, although inequalities remain.

Understanding and identifying the factors that lead to pension inequalities and how we as regulators, and others across the sector, can drive improvements is complex.

We have published a joint call for input with the FCA seeking views on the structural issues which impact the pensions consumer journey, which we believe include diversity-related inequalities. Through this call for input, we hope to determine whether we have identified how the journey can be improved to mitigate against these issues.

Through this we hope to secure feedback, answers and supporting data, which will help us to determine whether we have identified the right areas to explore further and help inform regulatory actions in the years to come.

Where we identify issues beyond our regulatory perimeter we will seek to work supporting others to deliver good outcomes for savers and be influential in national policy debates.

We want to go beyond our public sector equality duty to ensure that equality, diversity and inclusion run through the work we do. This will require a consistent and systematic approach. We want every member of our organisation to be clear about our strategy and action plan – and how they can contribute to a pension system that serves everyone. To achieve this, we will develop, with our people, key performance indicators (KPIs) for teams and individuals so they are clear about how they can actively contribute to our vision. These KPIs will, in turn, help us to refine and develop this strategy further.

We want to be influential in national policy debates, to lead by example and to support our regulated community to develop a more equal, diverse and inclusive pension system for the benefit of savers.

Objective 2

We will build our understanding on the issues that lead to pensions inequalities through our pensions consumer journey call for input, and work with others seeking to achieve good outcomes for all pension savers.

We will embed diversity and inclusion within our people, regulatory and operational practices by 2025, and the suite of KPIs we develop will enable us to measure our success.

Strategic aim 3

To promote high standards of diversity and inclusion among our regulated community: we will work with and influence the governing bodies that manage workplace schemes, providing positive support and encouragement to help them become more diverse and inclusive in their decision-making.

As we set out in our consultation the Future of Trusteeship and Governance: “A lack of diversity in the composition of pension scheme boards is something that has been recognised for a number of years.” For example, PLSA research in 2016 showed that more than 80% of trustees are men, and Aon’s research from the same year showed that the average trustee was male, 54 years old, with a university degree.

We believe that a governing body made up of people who have a greater range of backgrounds, life experiences, expertise and skills will tend to lead to wider discussion. Additionally, people challenging each other from different perspectives is likely to result in more robust decision-making. Inclusive governing bodies are those in which boards are more diverse, chairs take their inclusive leadership role seriously, and where contributions from a range of perspectives are valued. Building such boards will require commitment and support from ourselves and across the pensions industry. We recognise there is a long way to go in working with the pensions sector to truly become a more diverse and inclusive industry - for example by opening up access, developing and supporting talent, and taking action.

We are well placed to bring people together from across the pensions industry and engage with central government where appropriate. We want to lead by example and we are committed to taking real, serious change as an organisation. We also recognise that, as we enact our strategy, we will be learning and developing together with our regulated community to bring about transformational change.

We are already engaging with the pensions industry via our Industry Working Group. The first meeting of this was in January 2021 and the group will set out an action plan later this year. As part of this we will undertake a deep dive into the evidence base around the relationship between EDI and decision-making and explore options for a forum with our regulated community where best practice can be shared. With the group, we will explore the best ways to achieve this, for example whether facilitating an information hub would be useful.

We are also working with fellow regulators to explore how we can have a positive impact across the financial sector and learn from others who are on their own EDI journey, for example via our membership of the UK Regulator’s Network Diversity and Inclusion Network.

Objective 3

We will work with those we regulate on the increased development of diverse and inclusive governing bodies that are focused on improving outcomes for their members.

We will use our influence to increase diversity in the composition of governing bodies within our regulated community.

Roadmap: 2021 to 2025

Our vision is to deliver a workplace pensions system that works for everyone. As part of achieving this vision, we will deliver on the following EDI roadmap:

Corporate Strategy priority area	Strategic aims	Strategic objectives	Success measures
Bold and effective regulation	1. To be a fair, diverse and inclusive employer: as an organisation, we ourselves must become more diverse and create the right environment for our people to thrive and be their best selves. We will continue to build an inclusive culture in which our increasingly diverse community feels safe, supported and celebrated throughout their career at TPR.	We will actively set benchmarks and measure levels of inclusion within TPR with the commitment to take action to ensure marked improvement by 2025.	By 2022, we will measure our peoples’ experience of inclusion within TPR and set appropriate benchmarks to monitor this and act upon them. By the end of 2021, we will revise our Values and Behaviours Framework which will provide a foundation for transforming our culture.
		We will set challenging workforce targets to increase the diversity of our workforce.	By 2022 we will introduce an action plan to increase the representation of black and ethnic minorities and LGBT+ to at least 15% of our Executive Committee and senior leadership team. By 2025, we will establish a clear direction to increase representation of black and ethnic minorities, LGBT+ and people with disabilities by 20 percentage points across all levels of the organisation.
		We will publish an action plan by 2022 setting how we will reduce the pay gaps for under-represented groups.	By 2022 we will have a plan with specific actions to reduce TPR’s gender pay gap to 4% by 2024. By 2022, we will have action plans for ethnicity, disability and LGBT+ pay gap reporting.
Value for money	2. To build a collective understanding of why pensions inequalities occur and, within our regulatory remit, work in partnership with others seeking to reduce them: Recognising the need to lead from the front in affecting change in the pensions landscape we also want to go beyond our public sector equality duty to demonstrate the equality we want to see in the industry. We will therefore contribute to the ongoing development of the evidence base for why pensions inequalities occur, to inform evidence-based policy making and help support industry, fellow regulators and central government to achieve the best outcomes for all workplace savers.	We will build our understanding on the issues which lead to pensions inequalities and work with others seeking to achieve good outcomes for all pension savers. We will embed diversity and inclusion within our people, regulatory and operational practices by 2025. The suite of KPIs we develop will enable us to measure our success.	We are seeking views in our joint call for input with the FCA on the pensions consumer journey and will set out our evidence in its response by 2022. By 2025 we will achieve the National Equality Standard and explore participation in other national equality, diversity and inclusion charters, such as Business in the Community (BITC)’s Race at Work Charter, Stonewall Workplace Champions, Disability Confident Employers’ Scheme, and Mindful Employer.
Scrutiny of decision-making	3. To promote high standards of diversity and inclusion among our regulated community: we will work with and influence the governing bodies that manage workplace schemes, providing positive support and encouragement to help them become more diverse and enable them to be more inclusive in their decision-making.	We will use our influence to increase diversity and inclusion in the governing bodies of schemes within our regulated community.	By the end of 2021, we will co-create a strategy with representatives from our regulated community which will support and set targets for the development of more diverse and inclusive boards of trustees/managers. This plan will also agree how to share resources and best practice in the long term, for example via a ‘hub’.

Footnotes

[1] This document covers the financial years 2021-22, 2022-23, 2023-24 and 2024-25. It therefore runs between June 2021 and April 2025.

[2] What is the difference between sex and gender? - Office for National Statistics

[3] For the purposes of accuracy of reporting we have aligned with Civil Service terminology of LGBO (lesbian, gay, bisexual and other), i.e. this does not include transgender people (and transgender people are then included within the term ‘gender’). At TPR we cannot report on our workforce data regarding our transgender colleagues because the sample size is too small, and we would not be able to protect anonymity, so it is omitted from the gender calculations. We acknowledge that this does not reflect our efforts towards inclusion of the trans and non-binary community and we are working with our PROUD (LGBT+) diversity network to monitor the use of this terminology and how our reporting can be more inclusive going forward.