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Decision required

Commit to bringing forward a Wales Race Equality Action Plan setting out the framework for improving the life chances and outcomes of Black, Asian and minority ethnic citizens taking a pro-active anti-racist approach across Welsh Government.

Cabinet are also asked to consider:

How the Race Equality Action Plan for Wales can be owned across Welsh Government departments and implemented proactively?

How the “implementation gap”, identified by stakeholders across Wales, can be closed in order to end fragmentation between policy intention and practical impact.


  1. The COVID19 pandemic has thrown into sharp relief the continued and profound inequalities in our society here in Wales.  Evidence is clear that the disproportionate impact on Black, Asian and Minority Ethnic people cannot be explained by clinical, health-based data alone. This has been a shocking call to action to address the underlying structural and systemic racism, which is undermining the life chances of our Black, Asian and Minority Ethnic citizens. The work of Black Lives Matter and other rights-based organisations in Wales has amplified the call for much needed change. This has led directly to the commission of Professor Charlotte Williams to chair the Black, Asian and Minority Ethnic (BAME) Communities, Contributions and Cynefin in the New Curriculum Working Group by the Education Minister. It has also led to Gaynor Legall to be asked to chair the Slave Trade and the British Empire: An Audit of Commemoration in Wales Task and Finish group, by the First Minister.
  2. As a Government, we are committed to tackling inequalities. One of our wellbeing goals set out in the Wellbeing of Future Generations Act 2015 is: ‘a more equal Wales: a society that enables people to fulfil their potential no matter what their background or circumstances (including their socio-economic background and circumstances).
  3. As set out by the First Minister’s BAME COVID-19 Advisory Group and the report of its Socio-Economic Sub Group, the issues the pandemic has highlighted are not new and are reflected in wider data, literature and in the lived experience of our communities. A commitment to action is also not new, but the steps we have taken so far have not resulted in the kind of sustained and profound change we should be aiming for, nor have they addressed underlying structural and systemic racism.
  4. The development of a Race Equality Action Plan is our opportunity to reset our approach, to make a clear commitment to taking an anti-racist stance and to stimulate the cultural change required in adopting that stance.
  5. This will mean adopting a collective and conscious awareness of racism and making a proactive commitment to take specific action in a range of priority areas. The Race Equality Action Plan has the potential to be the catalyst for change that begins to dismantle structural and systemic racism in Wales; that amplifies the voices of Black, Asian and Minority Ethnic people and removes any barriers they face.


  1. To evidence (using data and the shared lived experience of stakeholders) why a novel approach to developing a Race Equality Action Plan is required, in order to achieve effective change.
  2. To acknowledge that current policy and practice has not gone far enough to dismantle systemic and structural racism in Wales and that there are a number of reasons for this:
    • that a culture shift within Welsh Government and across the public service is required to move from undertaking non-racist practice to anti-racist practice
    • that there is an implementation gap between policy intention and practice
    • that greater engagement with stakeholders is required to ensure that policy is informed by the lived experience of Black, Asian and Minority Ethnic communities.

Previous work to end racism in Wales

  1. The Welsh Government has undertaken significant work to address inequality throughout this term and prior. The Strategic Equality Plan 2020-2024 centralises Equality and Human Rights in the vision and work of the Welsh Government and sets out our commitment to fair treatment of every person, especially those who are most marginalised. Across our departments, we have important work underway to challenge inequality within specific activities and these initiatives are making improvements in several policy areas including employability, education and equalities work.
  2. However, we must accept that this has not enabled a sufficient focus on addressing race inequality and that our response feels fragmented to our stakeholders and the communities we serve. Our policy aims on race equality are unclear and lack accountability and strategic oversight. There is a clear “implementation gap” between policy intention and practice.
  3. We must also consider whether race inequalities have been overlooked across the Welsh Government and whether the lack of diversity in the Welsh Government Civil Service has been a factor. Stakeholders are critical of the Strategic Equality Plan for not making strong enough reference to race and our gender-focussed work has been criticised for neglecting the experience of Black, Asian and Minority Ethnic women. In recent weeks, we have seen high profile examples of the achievement and contribution of Black, Asian and Minority Ethnic communities being overlooked by key Government partners (the Women of Covid awards) and we see a lack of representation within the current crop of Saint David’s Day Awards nominees.
  4. Moreover, stakeholders report that since the Commission for Race Equality was closed and responsibility moved to the Equality and Human Rights Commission, there has been limited attention placed on the protected characteristic of race by Government and the Commission and that the lived experience of Black, Asian and Minority Ethnic groups has not been acknowledged or considered in depth.
  5. Racism exists on a spectrum, running from racist to anti-racist. In the middle of the spectrum is non-racism; a passive approach that does little to address inherent racial inequality. Previous work undertaken by the Welsh Government on race equality has been designed and implemented within a “non racist” perspective. However, in order to make the required change, the work of Government must take place in an “anti-racist” context; where an acknowledgement of the existence of structural and systemic racism underlines policy development and implementation and where equality outcomes are developed through an anti-racist lens. In doing so, the work will take account of the cumulative and historic nature of racial inequality, its inherent presence across systems, institutions and cultures in Wales and take an active approach to dismantling this.

Race inequality and racism in Wales

  1. There is a substantial evidence base related to race inequality in Wales and the wider UK, this data is summarised at Annex B. The evidence demonstrates cumulative disadvantages, illustrates a range of potential barriers to Black, Asian and Minority Ethnic people in Wales and shows the significant challenge to achieving equality of outcome across all groups. These range from higher risk for mothers during birth, higher likelihood of experiencing poverty and poor housing conditions, under service in education related to a significant lack of Black, Asian and Minority Ethnic teachers, lower educational attainment, experience of racist incidents and risk of bullying. Moreover, Black, Asian and Minority Ethnic individuals are disproportionately over-represented in our criminal justice system. Throughout their working life, employees from Minority Ethnic groups in Wales earn, on average, 1.4% less per hour than White British employees (further detail on these statistics and references can be found in Annex B). To quote the Runnymede Trust “Racial inequalities persist in almost every arena of British society, from birth to death” (Runnymede perspective, 2020).
  2. These inherent and cumulative disadvantages are symptoms of structural, systemic and institutional racism; our society is structured in a way (including via cultural norms) that excludes or presents significant barriers to Black, Asian and Minority Ethnic people from having equal life outcomes. The rise of populism and the apparent normalisation of overtly racist language, racist incidents and racist values is a compounding issue, which is creating challenges for community cohesion, as well as blighting the lives of BAME people.
  3. The impact of racism on the practices of social and political institutions (such as schools, governments and health services); from the way they discriminate against certain groups, whether intentionally or not, and to their failure to have policies that stop discrimination or discriminatory behaviour is termed institutional racism. It can be found in processes, attitudes, behaviours and cultural practices which lead to discrimination through unintentional prejudice, ignorance, thoughtlessness, unconscious bias and racist stereotyping which puts ethnic minority people at a disadvantage.

Addressing the implementation gap and achieving a shared understanding of anti-racism

  1. The Wales Race Forum and race equality organisations have called for a standalone strategy or plan on race for many years. This call was repeated in feedback from the consultation on the Strategic Equality Plan and also within the interim report of the Black, Asian, Minority Ethnic Engagement project, run by EYST and funded by Welsh Government. The Covid pandemic and its disproportionate impact on Black, Asian and Minority Ethnic communities has amplified this call and illustrated its necessity.
  2. Development work on a Race Equality Action Plan for Wales is underway and will be co-constructed with Black, Asian and Minority Ethnic people. The Plan itself is important and the actions it sets out will be key in practically demonstrating our commitment as an anti-racist government. However, the approach we adopt in developing the Plan, the relationships we build with Black, Asian and Minority Ethnic communities though the development process and the cultural change that we prompt as a result, is important in itself. We have, therefore adopted some novel approaches through which the Plan will be developed.
  3. The Plan will be guided by a rapid evidence review of the significant body of literature which exists in this policy area. This will be undertaken by the Wales Centre for Public Policy (WCPP) who will engage with subject experts, including academics from Black, Asian and Minority Ethnic backgrounds in Wales and beyond. Beyond academic literature, the WCPP will consider recommendations and reports made by our stakeholders in previous years and consider how best to address the “implementation gap” highlighted by stakeholders.
  4. The first task of the WCPP has been to identify evidence based priority areas to be considered in the Plan, to identify the key challenges associated with each of them and draw out what works in making progress to address them. The themes which are being developed are health and social care, education, employment and income, leadership and representation, the criminal justice system and housing and accommodation. Over the coming weeks policy officials, academic experts, community workers and the steering group membership will come together to consider each of these themes in detail, assess the evidence alongside the lived experience of communities in Wales and identify key areas for prioritisation.
  5. The intention of the evidence review is that it should help guide the actions we commit to in specific policy areas but also draw out the common themes and consistent barriers which are a reflection of the current structural and systemic issues. Going forward, the Welsh Government has accepted the recommendation from the BAME Covid-19 Socio Economic report to scope the feasibility of establishing a Race Disparity Unit in the Welsh Government to underpin the need for data to inform policy and practice.
  6. Professor Emmanuel Ogbonna, author of the BAME Covid-19 Socio Economic report is co-chairing a Steering Group to oversee development of the Race Equality Action Plan, with the Permanent Secretary. The senior leadership of the Steering Group reflects the priority we are giving this work and is important in building credibility with partners and Black, Asian and Minority Ethnic communities. The Steering Group members are senior stakeholders from the race and ethnicity sector and senior policy leads, nominated by the Director Generals, representing the policy themes which have emerged as priorities for the Action Plan. These policy leads will work with expert stakeholders (some in paid freelance roles known as buddies), and others, including Steering Group members, to develop the content of the Plan. This approach is the first of its kind.
  7. We have prioritised engagement, collaboration and co-production with our Black, Asian and Minority Ethnic stakeholders in an effort to address the gap caused by a lack of racial or ethnic diversity within the Welsh Government civil service by offering paid opportunities to Black, Asian and Minority Ethnic communities in Wales. Seventy-nine applications have been received for these roles.
  8. The Plan will also be shaped by the lived experience of Black, Asian and Minority Ethnic people and draw in as wide a range of voices and perspectives as possible. Twenty four grants have been awarded to community groups and forums across Wales to fund engagement opportunities that will centre Black, Asian and Minority Ethnic voices in the development of the Plan and ensure that the Plan is co-constructed with communities. Through the grants process we will receive information from amongst others, the Somali community in South Wales, people who identify as Black, Asian and Minority Ethnic and have mental health problems, Syrian refugees in a rural part of Wales and Gypsies, Roma and Travellers. A full list of funded organisations in at annex B. As part of the engagement, and in the evidence review, we will need to recognise and respond to intersectionality, and address priorities relevant to particular protected groups.
  9. The Plan will be published for consultation by the end of March 2021.
  10. The Race Equality Action Plan represents an important statement by Welsh Government of its vision, values, intentions and the practical actions it will take, to address racial inequality. There are a number of things we can do now to make change in certain areas and build momentum behind this work. These include actions around Welsh Government recruitment, more effective implementation of the Reflecting Wales in running Wales Diversity and Inclusion Strategy for Public Appointments in Wales (2020-2033) and continued action against the recommendations of the Socio-Economic Group report. However, an action plan made up of quick wins and short-term actions will not go far enough to address the significant concerns or expectations of Black, Asian and Minority Ethnic people in Wales, nor will it reflect accurately the experience of these communities. However, whilst the document and its content is important, of increased importance is the extent to which the Plan embodies and prompts the culture change that must take place in order to make a meaningful difference to Black, Asian and Minority Ethnic people’s lives in Wales.

Making the cultural shift

  1. Stakeholders and communities recognise the opportunity that the Plan and the timing of its introduction provide. They are encouraged and reassured by the action taken by the Welsh Government, particularly in response to the first wave of the Coronavirus pandemic and the leadership shown in relation to announcing the Plan.
  2. However, in order to go beyond achievements of the past and make the radical change required, fundamental differences in the Welsh Government approach must be in place.
  3. The first difference relates to addressing the “implementation gap”. Stakeholders note (and welcome) the strong policy approach of our Government but suggest that a lack of cross-Government leadership, accountability and oversight across the public service undermines the tangible impact this policy has on the lives of Black, Asian and Minority Ethnic people in Wales. Indeed, in many cases stakeholders are not asking us to create new policy but to ensure that previous initiatives be implemented fully to achieve the impact that they were intended to fulfil. Implementation of the Race Equality Action Plan must be owned by all Ministers and prioritised across all departments. Within the Plan we intend to provide implementation advice and information on accountability and monitoring to bridge the implementation gap.
  4. The second area of difference is the position from which we will take action. Previous work undertaken by the Welsh Government on race equality has been designed and implemented within a “non racist” perspective; no action has been designed to put Black, Asian and Ethnic Minority people at a disadvantage and aims to improve inequality. However, stakeholders are clear that, in order to make the required change, the work of Government must take place in an “anti-racist” context; this will involve an ongoing reflection of our own institutional process and a commitment to learn and undo certain processes whilst developing new policy through an anti-racist lens.
  5. Therefore, in order to demonstrate the required progress, we suggest the following:
    • The Plan must be owned and led by Ministers and senior civil servants.
    • The Plan and related work must be truly cross Governmental and understood, prioritised and sustained across each department and their delivery agencies.
    • Costs associated with the delivery of the Plan will be considered across all portfolios and factored into the 2021/22 Budget.
    • Implementation of the Plan should be prioritised and supported by performance indicators.
    • Commit to continuously understanding and delivering anti-racist services and practice and consider where in current policy work, and in Government levers for change, more could be done to address the needs of Black, Asian and Minority Ethnic communities and ensure equality of outcomes.
    • Agree that this Plan is long term and intensive in terms of outward engagement and internal change. It will require us to listen to the lived experiences of Black, Asian and Minority Ethnic people and demonstrate sustained commitment and leadership. It is anticipated that this will result in improved practice and outcomes for all the protected characteristics.


  1. In making the commitments outlined in this paper, the Welsh Government takes the first step towards the radical cultural shift required to achieve racial equality in Wales. Significant practical action will need to follow but, in combination, this work will seek to end the disadvantage that affects Black, Asian and Minority Ethnic people from birth to death.

Communications and publication

  1. No immediate communications work will be undertaken related to the decisions taken as a result of this paper. The forthcoming Race Equality Action Plan will reflect the commitments and a Written Statement will accompany its launch.


Commit to bringing forward a Wales Race Equality Action Plan setting out the framework for improving the life chances and outcomes of Black, Asian and minority ethnic citizens taking a pro-active anti-racist approach across Welsh Government.

Jane Hutt MS
Deputy Minister and Chief Whip
November 2020

Annex A: Statutory, finance, legal and governance matters

Statutory Requirements

In accordance with section 3 of the Wellbeing of Future Generations Act 2015 (“the 2015 Act”), the Welsh Ministers are under a statutory duty to set objectives designed to maximise its contribution to achieving each of the well-being goals, which includes the goal of ‘a more equal Wales’. The development of a Race Equality Action Plan has an obvious link to this goal. Work to develop the Plan will be undertaken in line with the sustainable development principle and the ‘five ways of working’ in section 5 of the 2015 Act. Most importantly through involvement and collaboration; lived experience of Black, Asian and Minority Ethnic people will be central to the Plan’s content.

The Welsh Ministers are subject to a duty to have regard to the UNCRC, when exercising their functions. This duty is imposed by section 1 of the Rights of Children and Young Persons (Wales) Measure 2011. To satisfy this requirement and also the Welsh Minister’s duties under the sustainable development principle, the plan will have a particular focus on Black, Asian and Minority Ethnic children and young people in Wales.

One of the aims of the Race Equality Action Plan is to assess and understand intersectionality with race. This plan will address the intersection between age, sex and disability amongst other relevant protected groups. Further work is planned to engage with these protected groups to understand their needs and to consider how these needs can be addressed within a Race Equality Action Plan for Wales. An Integrated Impact Assessment is also being prepared as part of the Plan’s development to ensure that the rights of all protected groups are considered in detail and early in the Policy formation.

The recommendations of the Socio Economic report (on which a significant proportion of the Race Equality Action Plan will be based) covers several issues related to children, including education, air pollution, visas, sponsorship and violence against women, domestic abuse and sexual violence.


The Welsh Ministers have a duty under the PSED in section 149 of the Equality Act 2010 to consider how their policies affect those who are protected under the Equality Act 2010. Under that section, the Welsh Ministers must, when carrying out their functions, have due regard to the need to:

  • eliminate discrimination, harassment, victimisation and other conduct which is unlawful under the Equality Act
  • advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it.
  • foster good relations between persons who share a relevant protected characteristic and persons who do not share it the different equality groups.

The production of a Race Equality Action Plan, which strives to address the racial inequalities in Welsh society, will clearly evidence the steps taken by Welsh Government’s to comply with the PSED with regard to the protected characteristic of race and where they intersect, with other relevant protected characteristics.

The Equality Act 2010 (Statutory Duties) (Wales) Regulations 2011 include specific requirements for relevant bodies (including the Welsh Ministers) to comply with in seeking to meet the general ‘due regard’ PSED duty under section 149 of the Equality Act 2010. The 2011 Regulations include a requirement to monitor and assess impact.

An Integrated Impact Assessment will be developed alongside the Race Equality Action Plan.

Finance requirements and governance implications

There are currently no direct costs associated with the Race Equality Action Plan for Wales. This paper seeks a decision to determine the way in which the policy initiative is to be developed.

However, as the policy initiative is developed there are likely to be financial implications in taking forward actions within the plan (not all falling to your portfolio). Longer term funding of the plan (beyond 2020-21) is highly reliant on cross-government support as the Central Services and Administration MEG does not have the levels of funding available for this moving forward. As we develop individual proposals in the Plan, cost will be a key consideration and subject to further consultation. Once these costings have been firmed up, further MA’s will be drafted which will need clearance from the respective ministerial portfolio relating to actions specific to that MEG.

We currently have a revenue and capital budget for 1 year, 2020-21, the period for which we have a funding settlement from the UK government. The availability and nature of funding from 2021 onwards will need to be considered as part of the Welsh Government’s Budget planning for 2021-22 and beyond following the outcome of the UK 1 year Spending Review due to be published on November 25. Investment will need to be prioritised within the MEG where the risk will lie once indicative allocations are available.

It will also be important to be mindful that any agreement to funding beyond 2020-21 will be placing a commitment upon a future government and will constrain their decision-making ability and potentially close down opportunities in other areas.

EPS Financial Clearance has been provided (EPS/JH/56/20). This paper has also been cleared by Strategic Budgeting (SB/1260/5).

Research and/or statistics

The research or statistics contained in the paper have been approved by Knowledge & Analytical services.

Annex B: A snapshot of the data

The following data is not presented to confer a sense of inevitability or to undermine the significant achievements and strengths within Black Asian and Minority Ethnic communities in Wales. It is provided to illustrate the systemic disadvantage experienced by Black Asian and Minority Ethnic people in Wales and, in some cases in the broader UK context, throughout every key life stage.


Black women in the UK are 5 times more likely to die in pregnancy than white women, the risk for an Asian women is double that of their white counterparts (Mbrrace UK, 2018, Mothers and Babies: Reducing Risk through Audits and Confidential Enquiries across the UK).

Deprivation and poverty

People living in households in Wales where the head of the household is from a non-white ethnic group are more likely to be in relative income poverty compared with those where the head of the household is from a white ethnic group. Over a third (34.9%) of people from a Black ethnic background live in the most deprived 10% of small areas and almost 11% of the people living in the most deprived 10% of small areas are from a BAME background. This is more than double the proportion of BAME people in the total population (Coronavirus (COVID-19) and the Black, Asian and minority ethnic population in Wales).

When considering the impact of Covid 19 on Black, Asian and Minority Ethnic women the Fawcett society found that 42.9% of Black, Asian and Minority Ethnic women said they believed they would be more in debt as a result of the pandemic, compared to 37.1% of white women and 34.2% of white men. 42.9% of Black, Asian and Minority Ethnic women say they would struggle to make ends meet over the next 3 months (Women’s Budget Group, The Fawcett Society London School of Economics and Queen Mary University of London. (2020). BAME women and Covid 19 – Research Evidence).

Housing standards

Half of the BAME population in Wales live in rented properties, compared to just under a third of the white population and BAME people who rent are more likely to live in privately rented properties than socially rented properties. We know from the Welsh Housing Condition Survey (2017-18) that the private rented sector generally has the oldest housing stock and a higher proportion of poor quality housing (e.g. containing damp or other hazards) - (Coronavirus (COVID-19) and the Black, Asian and minority ethnic population in Wales).


BAME children are very unlikely to be taught by anyone who looks like them (Education Workforce Council, Education workforce statistics). The Education Workforce Council's latest statistics suggest that 1.3% of teachers are from a Black, Asian or Minority Ethnic background - roughly 469 out of 35,171 staff in Wales, 0.2% specifically identify as Black, African. Caribbean or Black British, equating to around 64 teachers (Coronavirus (COVID-19) and the Black, Asian and minority ethnic population in Wales). In contrast, the latest school census indicates that 6.7% of pupils over 5 are of Black, Asian or mixed ethnicity (Schools' census results: as at January 2020). According to evidence provided by EYST to the Children, Young People and Education Committee there are no BAME head teachers in Wales (EYST, 2018).

According to Show Racism the Red Card (SRtRC), 4 out of 10 Welsh BAME students have suffered from racial discrimination and a fifth of children admit to using racist language against a peer in a school setting (Show racism the red card, 2020. Racism in Wales? Exploring prejudice in the Welsh education system). In recent years, gaps within ethnic minority achievement have generally been closing. However, attainment figures for some Black and Mixed ethnicities are below the national average for key stages 2-4 (StatsWales. Examinations and assessments). Gypsy, Roma and Traveller pupils have the lowest attainment overall (StatsWales. Examinations and assessments).

The Criminal Justice System

In England and Wales over the period April 2018 to March 2019 black people had the highest stop and search rates in every police force area for which there was data (Stop and search on GOV.UK) 91 black people from Wales are in prison, compared with 14 white, 28 Asian, and 41 mixed, per 10,000 of the population (Jones R, 2020, Prison, probation and sentencing in Wales: 2019 factfile).

Employment and income

Challenges remain in relation to employment and income; for the year ending March 2020 employment rates among the working age (16-64) Welsh population were highest among individuals with a White ethnicity (74%) and lowest among individuals with an Other ethnicity (52%) - (Annual Population Survey: July 2019 to June 2020). The equivalent rates among individuals with a Black, Asian and Mixed ethnicity were 66%, 64% and 71% respectively14. In addition, the ethnicity pay gap in Wales in 2019 was 1.4%. This means employees from Minority Ethnic groups in Wales earned, on average, 1.4% less per hour than White British employees (ONS, 2020. Ethnicity pay gaps: 2019).

There are also under representations of BAME people in politics and public life (UK Parliament, House of Commons Library, 2020. Ethnic diversity in politics and public life).

Annex C: Organisations funded to undertake community engagement to assist development of the Race Equality Action Plan for Wales

  1. Antur Teifi
  2. Avant Cymru
  3. BLM Wales and Race Council Cymru
  4. Cardiff University Centre for Islamic Studies and Muslim Council of Wales
  5. Diverse Cymru
  6. Henna Foundation 
  7. Hindu Cultural Association (Wales
  8. Hyatt Womens Trust
  9. KIRAN
  10. Mudiad Meithrin
  11. National BAME Youth Forum
  12. Neath Port Talbot BME Association
  13. NWREN
  14. North Wales Africa Society
  15. Privilege Café
  16. RCC – Cardiff Region
  17. RCC – Newport Region
  18. RCC – N Wales Region
  19. RCC – Swansea Region
  20. RCC – West Wales Region
  21. Sub Sahara Advisory Panel
  22. The Romani Cultural and Arts Company
  23. Women Connect First
  24. Tros Gynnal Plant
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