Anti-racist Wales Action Plan - Section A

In early 2020, the Welsh Government started work on an action plan for race equality, following calls by the Wales Race Forum, and other grassroots organisations. Almost immediately however, the work was halted by the COVID-19 pandemic. Then, in May 2020, the killing of George Floyd sent shock waves throughout the world. Both events shone a light on the systemic racism faced by Black, Asian and Minority Ethnic people, both in Wales and elsewhere. Both events reinforced the urgent need for action.

The COVID‑19 pandemic has had a disproportionate impact on people from ethnic minority communities. Over the past two years, a host of reports, inquiries and research have demonstrated this. This is underscored by social and structural differences, leading to health disparities and a range of other inequalities. A report in 2020 by the Chief Medical Officer summarised the challenges very starkly (see Appendix 7: References: Chief Medical Officers Report). The Runnymede Trust also highlighted this problem, stating that “racial inequalities persist in almost every arena of British society, from birth to death” (See Appendix 7: References: Runnymede, 2017).

The Welsh Government and others in the public and third sectors have previously pursued approaches such as ‘equality of opportunity’, ‘managing diversity’,” integration and assimilation”, “multiculturalism” and race equality to tackle institutional racism. These approaches had good intentions, but were often neutral in their execution. They failed to take enough account of unequal power structures, especially in relation to racialised power in our society.

They put too much emphasis for change on ‘fixing’ ethnic minority people or communities, not on fixing broken systems. In work settings, it is often implied that ethnic minority people do not have enough qualifications, or didn’t network enough, or need more training.

We know that highly qualified ethnic minority people work in our health services, and in other public and private organisations. But it is the nature of recruitment and progression that works against them; it is the systems for selecting those who achieve progression, those who get mentored, coached and sponsored, that fail them. In the provision of services, it is often the ‘colour‑blind’ approach that ignores pre‑existing racial imbalances that affect outcomes, that fails them. Such systems are, in effect, ‘rigged’ against certain groups. Consequently, they struggle to enter and progress, or to obtain services appropriate to their needs.

Through the development of the plan we heard a clear message about the lack of trust felt by many people from ethnic minority backgrounds, over whether public bodies will enforce their rights, rights enshrined in law, but which often have little real impact on their lives. In this new plan we outline how we have developed more focused actions, to help us make the necessary changes, and to fix broken systems.

We acknowledge the actions set out in the plan represent the key steps to be taken during the next 2 years or so. We are committed to be developing and publishing further actions, as implementation progresses on an on‑going way.

Commissioning

In the summer of 2020 Jane Hutt MS, the Deputy Minister responsible for equalities, asked officials to resume work on a new Race Equality Action Plan. She invited Professor Emmanuel Ogbonna from Cardiff University and Dame Shan Morgan, then Permanent Secretary at the Welsh Government, to co-chair a Steering Group to oversee the work. The Group included people from organisations, academia, and others with in-depth knowledge and experience of race and racism. Throughout the process, the Group played a central role in shaping thepPlan.

Pre-consultation: how the work was done

During this initial period, a host of pre‑consultation events, meetings and discussions took place, in order to identify priorities and to co‑design the draft plan. This work included:

• evidence Review: we commissioned the Wales Centre for Public Policy at Cardiff University to carry out a rapid evidence review of reports and research in relation to race equality (See Appendix 7: Reference: WCPP report)
• we commissioned an internal review of ‘What the evidence tell us’, as outlined in the draft plan
• face to face meetings: we held a series of meetings with grassroots organisations and individuals
• work by the First Minister’s Black Asian and Minority Ethnic COVID-19 Advisory Group: and its sub group and incorporated them into this work (See Appendix 7: References: Black, Asian and minority ethnic advisory group report)
• discussions with the Wales Race Forum
• work by Black, Asian and Minority Ethnic Communities, Contributions and Cynefin in the New Curriculum Working Group and The Slave Trade and the British Empire: an audit of commemoration in Wales (See Appendix 7: References: Cynefin report)
• setting up and working with the Anti-racist Wales Action Plan Steering Group (See Appendix 1)
• community Mentors, and experts on anti-racism policy: We asked 17 ‘Community Mentors’ to support and advise policy officials on ethnic minority people’s lived experiences (list at Appendix 2). We also invited a number of experts with particular understanding of racism in policy work to help us; this helped us to clarify and strengthen many of the actions
• a series of ‘Community-led dialogues: We held a series of engagement sessions with ethnic minorities, including women, young people, Welsh speakers and others. (list at Appendix 3: organisations supporting the dialogue and later consultations)
• commissioned an analysis of community lead dialogue reports (See Appendix 7: References: Community engagement analysis)
• policy themed events: we held several events to bring together different partners working on the evidence base, involving academics, activists and individuals with expertise and lived experience. These had a profound impact on how the actions were shaped
• assessing Impact: the plan has been specifically designed to tackle institutionalised and systemic racism experienced by Black, Asian and Minority Ethnic people. This is designed to have positive impacts on Black, Asian and Minority Ethnic people in Wales. The intersectional nature of institutional and systemic racism is recognised in the Goals and Actions. The most significant positive impact of the Plan is that in making the commitments outlined within it, the Welsh Government is taking the first step towards the radical cultural shift required to achieve an anti‑racist nation by 2030. By involving people differently, we better understood the impact our draft Goals and Actions would have on the lives of Black, Asian and Ethnic Minority people (see chapter 5 ‘What you told us, and how we’ve responded’). This helped us look at impacts in an integrated way and support our continued assessment of impact through our Integrated Impact Assessment approach. The impact of the proposed Goals and Action was developed and recorded in the Integrated Impact Assessment (IIA) tool which includes a Children’s Rights Impact Assessment, Equality Impact Assessment and consideration of the Well‑being of Future Generations obligations. The first version of the IIA was published alongside the draft Race Equality Action Plan consultation (March 2021) and we will publish an updated conclusion, and continue to use this as a live resource to inform the implementation of the Plan and how we measure and monitor change.

Early messages

During this period, some clear themes emerged, which informed the consultation document. These are summarised below:

• a strong feeling that people wanted a practical document focused on anti‑racism. They did not want “yet another strategy” aimed at equal opportunities, integration or multi‑culturalism. However what an anti‑racist action plan looked like needed further collective agreement
• a clear belief that public, private and third sector organisations were not meeting their obligations to dismantle systemic and institutional racism. In particular, that many public bodies were not compliant with the Equality Act 2010, and not meeting the public sector equality duty
• acknowledgment that without proper messaging, the plan could alienate some in the White community. There was a strong belief that promoting fairness and equity for ethnic minority people and communities does not conflict with supporting other disadvantaged groups and we should highlight the separate work being done on those issues
• doubt as to whether the Welsh Government could incentivise action or apply sanctions when progress was not being made
• a view that regulatory bodies, inspectorates and ombudsmen do not have a good understanding of racism, how it is embedded in their policies and practices, or of what to do when they encounter it
• a feeling that generic Diversity and Inclusion plans within the public sector were often insufficient. Many felt they resulted in a lack focus on race issues
• a call for the Welsh Government to address the differing and intersecting needs of ethnic minority women, children, disabled people and those of all other protected groups

Our approach to understanding and implementing anti-racism, has been informed by academic experts and experts by lived experiences working in the field of anti-racism. The Welsh Government is doing this in a new way, because we want to avoid ‘doing what we always do’, and repeating mistakes made in the past.

The old approach resulted, unsurprisingly, in a belief by ethnic minority people that real change was not possible. In this plan, we are making a genuine effort to do things differently.

In adopting the vision of a Wales that is anti‑racist, and in naming this plan the “Anti‑racist Wales Action Plan”, we are taking an anti‑racist stance. We are acknowledging that institutional and structural racism exists and needs to be tackled actively and assertively.

During the consultation, people asked us to be clearer about what we meant by this. They wanted to know what an anti‑racist approach would mean in practice. They wanted us to be bolder in tackling systems that negatively impact on ethnic minority people.

Professor Ogbonna has highlighted that:

“Racism is constantly mutating. If we fail to eradicate it, it will continue through generations. It becomes a perverse inheritance that expresses itself in different mutations, and that blights the lives of future generations in different ways.

Many years ago, racism was overt, with many ethnic minority people told directly that they were not wanted. Today, racism has morphed into subtle everyday behaviours but is no less pernicious in

its impacts. We want to eradicate racism and we believe that adopting an anti-racist approach is the key to this”.

We adhere to the formal definition of institution racism defined in the Macpherson report (1999):

“The collective failure of an organisation to provide an appropriate and professional service to people because of their colour, culture or ethnic origin. The report argues that institutional racism can be seen or detected in processes, attitudes, and behaviours that amount to discrimination through prejudice, ignorance, thoughtlessness, and racist stereotyping which disadvantages minority ethnic groups.”

For us, we have defined anti-racism as:

“Actively identifying and eradicating the systems, structures and processes that produce radically differential outcomes for ethnic minority groups. It involves acknowledging that even when we do not regard ourselves as ‘racist’ we can, by doing nothing, be complicit in allowing racism to continue. It is not about “fixing” ethnic minority people or communities, but rather about fixing systems that have not benefited and at times even damaged ethnic minority people. It is about working with the considerable strengths and leadership of ethnic minority people and using their lived experiences in how we, collectively, shape and deliver. It is about making a positive and lasting difference.”

Developing negative stereotypes about ethnic minority people can start as early as age four; so even those who think they are non‑racist can have ingrained stereotypes which may, if combined with a position of power, result in negative behaviour towards ethnic minority people. The pervasive nature of racism can affect all ethnic minority people, irrespective of rank and seniority, and can be multiplied when combined with another source of oppression e.g. due to gender or disability.

Failing to adopt an anti‑racist approach means that behaviours deemed benign may still impact negatively on people from ethnic minority communities.

We should start to scrutinise our individual biases, and reflect on how they may impact on members of minority ethnic communities. We should also acknowledge the power we hold, both individually and collectively, to tackle broken systems. This will help us to understand why there is racism in society, how it is embedded in our ways of working and delivering services, and what we can actively do about it.

We also wish to emphasis the role of White people in being active allies for this work. Being an ally means that we take responsibility for actively making the necessary changes.

In developing our goals and actions, we decided to take radical rather than incremental steps. We want action that is different from before. The solutions will vary between policy areas, and this is reflected in the plan.

After considerable efforts to co-design an action plan, we formally consulted on a draft action plan between March and June 2021. We received over 300 responses. We want to thank and honour all these individuals, groups and organisational contributions, in particular the many people who took the difficult step of sharing their own painful experiences of deep racism, and of the impact this has had.

We also want to thank those individuals and organisations who led the dialogue and debate on our behalf. We are also very grateful to Race Equality First, who went beyond the call of duty and who analysed every response for us. We present as much of the full report as we can in order to do it full justice and as a record of the strength of the concerns and contributions made.

We summarise below the key messages from the consultation, and how these have been taken into account in this final version of the plan.

Terminology

The term 'Black, Asian and Minority Ethnic' used in the consultation draft, and the short version ‘ethnic minority people or communities’, attracted many differing comments. Feedback from Gypsies and Traveller people was stronger, they felt the term simply didn’t apply to them or include them. Identity is extremely personal and people who experience racism are not a homogenous group. Rather, they consist of a wide variety of different cultural and ethnic groups often with very different positions within British society. It was clear from the response that the preferred position was to be as specific as possible and to refer to people the way they would prefer themselves to be referred.

There will be occasions where it is necessary to refer to the collective experience of racism. As expected, the consultation did not result in any one term firmly standing out from others as the preferred option.

Following a further discussion with the Anti‑racist Wales Action Plan Steering Group, we agreed to keep the term ‘Black, Asian and Minority Ethnic’ along with ‘ethnic minorities’ as a short version. A key point raised was to ensure that we used ‘people’ over ‘communities’ wherever possible. This is to emphasise the humanity of those who have experienced racism and have been minoritised. Often they are a global majority.

It is also important to point out that whilst collectively discussing racism against a group of people, these terms can be helpful. However, when in workplaces or services, allowing people to express their identity in the way they choose is important.

We were also, rightly, challenged about a lack of clarity and visibility of the experience of Jewish people and people of Islamic faith as included in groups experiencing racism. We want to emphasise that in addressing racism we include these groups and the racism they experience.

The Welsh Government has adopted the International Holocaust Remembrance Alliance’s working definition of antisemitism which is:

“Antisemitism is a certain perception of Jews, which may be expressed as hatred toward Jews. Rhetorical and physical manifestations of antisemitism are directed toward Jewish or non‑Jewish individuals and/or their property, toward Jewish community institutions and religious facilities.”

We add that we prefer to say “Jewish people”.

The All Party Parliamentary Group on British Muslims and the Runneymede Trust both define Islamophobia in terms of racism directed at Muslims, highlighting the way in which Muslims have become collectively racialised through their religious identities. It is important thus vital that prejudice, discrimination, bigotry, and inequality facing Muslims is considered in addressing racial equality here in Wales. This is not to undermine the importance of religious identity to Muslims, but rather to recognise the way in which racism impacts different communities in different ways.

There were also comments on the term ‘lived experience’. Some pointed out that their lived experiences were not solely what individuals brought, they also brought their professional expertise, for example, as health workers, social care workers, teachers or academics. The preferred term proposed was ‘experts by lived experience’.

Vision, purpose and values

We have worked within the good practice and momentum offered by the Well Being of Future Generations’ Act and the five ways of working as core to this work. The Act is about improving the social, economic, environmental and cultural well‑being of Wales now and in the future.

It makes public bodies listed in the Act think more about the long‑term, work better with people and communities and each other, look to prevent problems and take a more joined‑up approach.

The intentions of the Act can only be realised if we are working actively towards equity in wellbeing for everyone in Wales now, and in the future. Addressing racism and the disparities it has created and continues to sustain are fundamental to the purpose of the Act. Anti‑racism has to be central to the implementation of the Act otherwise it risks perpetuating existing injustice.

This purpose is reflected in the specific wellbeing Goal which is: “A society that enables people to fulfil their potential no matter what their background or circumstances (including their socio economic background and circumstances)”. However, the goals must be seen together and none can be achieved without transforming the wellbeing of ethnic minority people living today and of future generations to come.

In developing the vision, values and purpose of this work in a way that was led by and endorsed by ethnic minority communities, we have embedded the sustainable development principles of long term, prevention, integration and collaboration at the heart of this work.

The vision, purpose, values and goals of this plan, as stated in the draft consultation were:

Vision

Wales as an anti‑racist nation.

Purpose

To collectively, make a measurable difference to the lives of Black, Asian and Minority Ethnic people.

Values

Openness and transparency, putting people’s lived experiences at the heart of the work we do, and adopting a rights‑based approach.

The vision, purpose and values were widely welcomed in the responses. Regarding timescales, some felt it was too ambitious to achieve the plan’s purpose within ten years, due to the extent of the cultural and behavioural changes needed. Many also questioned where the actions in the consultation paper would achieve this vision.

We agreed. Racism has been systematised and institutionalised over generations, so it will take a significant time to change. The vision may take longer than 10 years to realise, but we need a picture of what it may look like in order to move forward, and we want to make progress as quickly as we can. Our purpose is to collectively make a measurable difference to the lives of Black, Asian and Minority Ethnic people. This has to happen through the collective efforts of Government, public, third and private sectors. We have therefore amended the purpose to include the word 'collectively'.

For the purpose of monitoring change we have responded to comments about the large number of statements in the draft plan about what good looks like by 2030 if we move towards becoming an anti‑racist nation and revised and condensed them. We list them in the section entitled “How we will deliver this plan”, and explain how we will use this material to measure change over time.

Goals

In our draft consultation we laid out of the Vision, Purpose, Values and Goals as below and this remains the same.

In this, the final plan, we have amended the Goals, as below.

The cross‑cutting element and the Environment actions have gone. The cross‑cutting elements are now reflected in our section on Leadership within the Welsh Government and in relation to public services section, and the Environment section is awaiting further work. We are committed to including action on Climate Change and Environment in the coming months.

We give some explanations on each of the areas of the Goals we have actions in section B.

Goals and actions

Some respondents were concerned that we were trying to achieve too much, and/or not prioritising the right things for tackling systemic and institutional racism. Others felt the sheer size and extent of the draft plan (64 Goals and 340 Actions) meant that impact, and overall understanding, were at risk of being lost.

We have reflected on this and have focused the final actions on tackling institutionalised racism.

Others felt that the draft Goals and Actions were not sufficiently ‘SMART’ i.e. specific, measurable, achievable, reliable and time bound. In the consultation paper the goals and actions were listed as ‘short term’, ‘medium term’ and ‘long term’. This was partly done to test the appetite for particular actions. However, respondents felt these terms were too imprecise. Since the consultation period we have worked with policy leads to sharpen the actions with clearer outcomes and timescales. We have also attached responsibility for every action to a named part of the organisation.

This revised plan only covers actions to be undertaken between June 2022 to June 2024. We will learn from the work we do in this period and will develop revised goals and actions for the subsequent period.

Others felt the document had too much jargon and ‘policy speak’. They felt we were not explaining the changes we were looking to make in simple enough terms. So, we have tried to simplify things, by focusing on changes we wish to collectively make to people’s experiences of racism in 6 different aspects of their lives:

• Their experience of racism in every‑day life.
• Their experience of racism when experiencing service delivery.
• Their experience in being part of the workplace.
• Their experience in gaining jobs and opportunities.
• Their experience when they lack visible role models in positions of power.
• Your experience of racism as a refugee or asylum seeker.

Policy officials have used these headings to guide their action plans. In our published Introduction to anti‑racist Wales we share some examples of how we are addressing people’s different experiences in different policy areas.

Multiple discrimination/‘intersectionality’

Some concerns were expressed that we were only focusing on one protected group, and that this took a simplistic approach to the different ways racism works to impact on ethnic minority women, children, older people, disabled people, and other protected groups. Many commented that an awareness of how these differing characteristics interplay, to create greater disparities, was not sufficiently visible in the draft plan.

Kimberlé Crenshaw, a Black feminist, coined the term ‘intersectionality’ to describe the combined effect of multiple forms of oppression, and how they interplay and are interconnected (Crenshaw K, 1989.)

We recognise that ethnic minority women, for example, carry a heavier burden in their experience of racism, for example through their direct experience with maternity services, or in leading engagement with schools or social services on behalf of their elders and families. We also recognise that young ethnic minority men, for example, are more likely than other groups to be stopped and searched by the police. Similarly, the systems and processes that impact on refugees and migrant workers are very different to those affecting ethnic minority people with the permanent right to live in Britain.

Socio‑economic circumstances or ‘class’ plays an additional role in keeping ethnic minority people oppressed. Ethnic minority people in Wales are more than twice as likely as White people to live in the 10% most deprived parts of Wales (20.6% of ethnic minority people compared to 8.3% of White people). Black people are most likely to live in the 10% most deprived parts of Wales, with 35% of all Black people living in these areas. More than 1 in 10 people living in the 10% most deprived areas are from ethnic minority groups, despite only making up 5% of the total population in Wales (Welsh Government, 2020).

In recent years, we have sought to improve the experience of people with specific protected characteristics through a series of action plans. These include the Gender Equality Action Plan,

the Nation of Sanctuary Refugee and Asylum Seeker Plan, the Enabling Gypsies, Roma and Travellers Plan and the Right to Independent Living Plan. Other plans are also in development, including the LGBTQI+ Plan, and work by the Disability Rights Taskforce in response to the ‘Locked out: liberating disabled people’s lives and rights in Wales beyond COVID-19’ report. Please see Appendix 7 for links to these plans.

These plans consider complex and challenging experiences and set out a series of actions to mitigate the potential negative impacts associated with them. It is important that these characteristics are not considered in isolation. Consideration must be given to how a protected characteristic interacts with other factors, such as gender, sexuality, disability, age, faith, socio‑economic status or class. One single form of discrimination cannot and should not be understood in isolation from another.

Many of the themes in this plan are repeated within other plans because they apply to the experience of combined protected characteristics. We recognise that actions and goals within this plan which aim to address the experience of ethnic minority people in Wales do not always address race or ethnicity in isolation. Often, they address the experience of intersecting characteristics.

The power of this plan (and others) will depend on our approach to implementation. An intersectional approach will be crucial. So the Accountability Group will consider and draw‑in expertise from across a range of protected characteristics, to ensure that combined impacts are considered, as the plan is put into action.

Governance frameworks for all other equality plans will also be adjusted for the same purpose, and reporting mechanisms identified and put in place.

Measuring and monitoring change

Measures and indicators: The consultation paper did not include specific performance indicators as we were testing the appetite for the particular actions before confirming details. So respondents were concerned that we were not being transparent about how we would monitor change, either quantitatively (with numbers and statistics) or qualitatively (e.g. through interviews, or people’s accounts of lived experience).

Compliance with the Equalities Act

The consultation responses suggested that the failure to reduce racism was due, in part, to government, public, private and third sector organisations not fully meeting their duties under the Equalities Act 2010.

It was suggested that the Public Service Equality Duty under the Equality Act 2010 needed to be fully met, and that the powers under the Act should become central to the implementation of this plan. We agree. We will ensure that we hold ourselves, and those we fund, to account in meeting this Duty.

To help with this, we have identified a set of five core actions for all public bodies to progress, linked directly to the provisions of the Equality Act 2010. Our newly established Race Disparity Evidence Unit will track progress with this. These 5 core actions are explained more fully in the Leadership in Welsh Government and across public sector section.

Resources

A key concern for many consultees was whether this plan would be supported by proper resources. As a result, the Welsh Government has reviewed the resources it makes available to (a) the teams that will coordinate and monitor the plan, (b) to the relevant policy leads, and (c) for the work with external stakeholders and communities.

Different Ministers, across all portfolios, have committed to make an appropriate level of resources available across Welsh Government, to deliver the goals and actions in this plan. Funding has been made available, within the Welsh Government’s budget, to support this.

In developing detailed actions in different policy areas, the level of resources required to implement them have been identified and agreed. For example, the Welsh Government has committed funds to support a central Implementation team to oversee the implementation plan, to establish the Race Disparity Evidence Unit, and to support the work of the External Accountability Group.

In addition, we are being very clear about how we will use our wider budgets and spending and programme budgets to drive anti‑racist action.

The ‘Anti-racist Wales Implementation team’ will lead on the development, implementation and monitoring of the goals and actions. We will also review the criteria and priorities for our Equality and Inclusion grants, with a view to establishing a better dialogue with ethnic minority communities across Wales.

The leadership challenge

A concern was raised that giving responsibility for promoting anti‑racism to a ‘champion’ within an organisation may backfire, by encouraging other leaders to avoid action or accountability. Many suggested that all leaders should champion anti‑racism.

We believe that the leadership challenge that permeates all the goals and actions is to reveal the systems and processes that have a negative impact on ethnic minority people, and to do something active, bold and different to tackle these. It requires leaders to reflect, and to tackle the “cause behind the cause.” This is the challenge we will be asking leaders at all levels of our organisation to understand, and which we will support them to act upon.

This requires leaders to prioritise anti‑racism, and to give a clear message about the importance of being brave and radical, and to live these behaviours themselves. As ‘Allies’ they will be need to engage in difficult conversations that take on board people’s lived experiences and to initiate and sustain change. It also requires leaders to identify those systems and processes that result in different, negative outcomes for ethnic minority people, and to ensure that changes occur. Calling out racism wherever they see it and committing to making unbiased decisions is also critical.

We will enable leaders to understand that anti‑racism requires them to listen, however discomforting, and to be creative about possible solutions. They should co‑design solutions with ethnic minority people, as they have the real knowledge of the changes that are needed. For their part, policy officials and other public servants have knowledge about the tools that exist to make change. We need everyone to have this knowledge as we see leadership to be a part of everyone’s role, not just those who occupy senior positions.so they can be equal partners in implementing new and effective solutions.

We will also work with leaders in the public services, third sector and those we fund in the private sector to gain rapid ownership of this plan. We will hold dialogue sessions but also contract via our policy work with those enable or regulate on our behalf to use the levers they have to their full effect.

Finally and most importantly, we wish to ensure that this plan recognises the strengths of the leadership within the ethnic minority communities. Leaders at all levels in society have fought racism for many generations and for many years, and left unrecognised and often excluded from decision making that effects ethnic minority communities and wider. Their resilience and tenacity in continuing the fight against racism needs acknowledging, and their considerable strengths and insights in how systems work to elude and discriminate is critical to this work and indeed to good practice for all.

These include strengths reflected in the consultation and at every level of society – of individuals who have suffered the trauma of racism and shared their lived experiences in open forums, of groups who lobby and/or act on behalf of others, often without payment and organisations who stand up against racism and call out racism. This leadership carries a particular burden, one of enduring scars of racist experiences. As the Welsh Government we respect and value the work they do, support their efforts and acknowledge that without them this plan would not be possible.

Our leadership commitment is to support and develop the capacity and capabilities of leaders from the ethnic minority communities. We have identified actions within our Leadership within the Welsh Government and across public services section.

The role of the private sector

There was a concern that the plan did not focus enough on the private sector, or on actions that can influence the private sector. This presents challenges because we do not hold as many direct levers with the private sector as we do with the wider Welsh public service. We will aim to use our funding more effectively with the private sector through our grants and procurement processes to ensure organisations in receipt of our funding demonstrate a commitment to anti‑racism.

To deliver the ambitions of the plan, we will need to use our influence and persuasion as an exemplar employer. By encouraging both the public and private sectors to work together with recognised trade unions in social partnership, we will encourage more robust and effective decision‑making processes, and the creation of an anti‑racist culture.

The Wales TUC represents Trade Unionists in all sectors in Wales and plays a significant role in tackling racism in the workplace. We will work with the Wales TUC, employers, and other partners to improve the experience of work and the adoption of anti‑racist approaches.

Resistance to the action plan

Although there were many constructive responses from public services, there was also some evidence of resistance to the plan and its ambition. This was reflected in responses which questioned the need for a plan, given existing legislation and other relevant action plans and strategies. There were also questions about the relevance for different parts of Wales, funding and resources and discomfort with proposals around accountability for change.

We recognise that adopting an anti‑racist approach represents a significant shift in our approach to addressing racial disparity and racism in Wales. There is limited expertise in Welsh public bodies, including Welsh Government, in embedding anti‑racist practice on a sustained basis. We need to work together across public services to provide leadership on this issue and build capacity.

However, we make no apology for having a very clear and direct focus on race and ethnicity and the imperative to address structural and systemic racism.

The case for change is overwhelming. If change was going to come as a consequence of existing legislation, plans and strategies, and different approaches e.g. multi‑culturalism race equality, inclusion and diversity etc., we would have already have seen it. This plan, and its accountability arrangements, is about having a sustained focus on these issues and ensuring that as a minimum, existing legislation is complied with.

When embarking on this work to develop this plan there was a clear call by ethnic minority leaders working with us that they did not want another strategy, and further, another plan that did not deliver on its promises. How we ensure that the implementation takes place effectively and does not falter along its journey has been central to the discussion with the Steering Group and people within the ethnic minority groups.

We have put in place 3 key elements to reassure on these concerns; clear measures of success, including indicators, independent governance arrangements and commitment to resources.

Clear measures of success, including indicators for success

When we developed our Vision, values and purpose statements with the ethnic minority communities, we also identified a series of statements about what “good” would look like if we moved significantly towards being an anti‑racist nation by 2030.

Based on feedback, we have revised and drafted these to include the below. They cover 6 areas of concerns.

In relation to ethnic minority people’s resilience and success despite racism experienced.

Statement of desired changes:

1. The Welsh Government will have funded and supported community‑led organisations in an open and fair way.

2. Policy development and the design of service provision includes a diverse range of voices from Black, Asian and Minority Ethnic communities at regional and national level, using their lived experiences to find creative solutions to policy and service development and delivery.

In relation to ethnic minority people’s experience of racism in every-day life.

Statement of desired changes:

1. Black, Asian and Minority Ethnic people are aware of the complaints procedures when accessing public services and are able to access those in the language which they require when needed without any fear, barriers or retribution.

2. The police service in Wales proactively tackles racism and works with Black, Asian and Minority Ethnic people and the wider community to improve community cohesion in the delivery of police services.

3. The justice process in dealing with racism is reviewed in collaboration with Black, Asian and Minority Ethnic communities.

4. Physical and online Hate crime is eliminated.

In relation to ethnic minority people’s experience of racism in service delivery.

Statement of desired changes:

1. Black, Asian and Minority Ethnic students and their carers have confidence that education settings have effective policies to prevent racist bullying / micro aggressions and that these are dealt with effectively when they do occur.
2. Black, Asian and Minority Ethnic people experience improved access to public services which are equitable and culturally appropriate to their needs.
3. Public sector providers are culturally aware and competent in delivering services to Black, Asian and Minority Ethnic people which recognises the differences amongst ethnic minority groups.
4. There is zero tolerance to racial discrimination or inequality in public sector service delivery.

In relation to ethnic minority people’s experience of racism in the workplace/racism in gaining jobs and opportunities.

Statement of desired changes:

1. The public sector workforce in Wales represents the population it serves at all levels of the organisation.
2. Improved identification and promotion of practice that works in reducing employment inequalities, discrimination and barriers for Black, Asian and Minority Ethnic people in all aspects of recruitment, selection and career progression.
3. Leaders and senior management in public and third sector demonstrate how they are working to embed anti‑racism within the organisation as a mandatory aspect of their performance management.
4. All staff in public sector and funded bodies receive mandatory training on anti‑racism.

In relation to ethnic minority people’s experience when there is a lack of visible role models in positions of power.

Statement of desired changes:

1. Public, private and third sector organisations have senior leadership that is representative and inclusive, as are all Boards of public bodies.
2. A diverse Welsh Senedd that is representative of its communities.
3. Public, private and third sector organisations develop Black, Asian and Minority Ethnic people to take up ‘positions of power’.

In relation to ethnic minority people’s experience of racism in areas beyond the control of Welsh Government (non-devolved areas) for example in your experience as refugees or asylum seekers.

Statement of desired changes:

1. Those seeking asylum and refuge in Wales are aware of their rights and entitlements, and are able to access them.
2. Wales is seen as a safe place to live by new arrivals and also existing communities.
3. Welsh Government uses its levers to ensure it influences non‑devolved areas.

These are in draft and are being further developed and refined by a mixed group of community leaders, civil servants and public servants from outside the Welsh Government.

We have started to design a draft Strategic Progress Measurement Framework to become the main reporting tool for the plan. Once developed, the framework will be further discuss with the newly set up Accountability Group (see below). It will show the progress the Welsh Government, public sector and funded organisations are making towards the purpose and the vision, against a set of strategic indicators. Work on it is ongoing and will be developed in autumn 2022 when we have the right resources and expertise to do this work.

The draft proposes that the measures will be measured at 2 levels:

1. the Strategic Performance Measures (SPMs), will measure change across the Welsh Government, public and funded sectors. The SPMs are, on the whole, intended to be generic, and so applicable to any policy area, across all sectors.
2. the Operational Performance Measures (OPMs), will measure progress against the goals and actions set out in the action plan. Each respective policy area will have to consider how it will ensure effective measurement of the changes and outcomes arising from its actions. Each will need to develop its own OPMs and include appropriate actions.

Some of the ways we will measure change will take some time to implement. For example implementing new surveys, making changes to questions in major surveys, or changing sampling to ensure adequate ethnic minority people’s representation to enable data to be presented in an appropriate more detailed/granular way.

External Independent Accountability Group

To offer additional and continuing confidence that this plan is being implemented, in agreement with the Steering Group we have agreed the Terms of Reference an external, independent ‘Accountability Group’ to oversee this work. (See full Terms of References at Appendix 5). It will mainly consist of ethnic minority people, and will be further strengthened by including experts by lived experience of racism. They will have expertise in racial disparities, and in ways to tackle institutional racism in different areas, for example, health, social care, education, employment, and refugees. All will be recruited in an open and transparent way. We will look for a spread of expertise, lived experience, and views.

This independent Accountability Group will be led by Professor Emmanuel Ogbonna, from Cardiff University and Dr Andrew Goodall, Permanent Secretary at the Welsh Government. It will have regular access to the Minister for Social Justice, and the First Minister and other Ministers.

The Accountability Group’s core focus will be ensuring delivery of the plan, monitoring progress on actions and commitments and ensuring momentum is maintained. The plan includes pan‑public service actions and priorities, which require collective commitment across Welsh Government and public service leadership but will also require specific actions from particular sectors, including health, housing and local government. The Welsh Government will ensure commitments are monitored and progressed through many public service and third sector organisations through mechanisms such as remit letters or funding commitments and through political engagement between Ministers and councils.

We will also have an internal Welsh Government group, called the 'Internal Challenge and Support Group', which will guide the different departments’ work. Its role will be to ensure that we are ‘joined‑up’ across different policy areas. (See full Terms of References for this group at Appendix 6.)

We value the conversations we have started with ethnic minority people, and so we also intend to develop local forums, across Wales, to help us continue this conversation.

The consultation also revealed concerns over whether the Welsh Government would have the right tools and structures to hold other bodies to account over this plan. Its existing levers include legislation and guidance, contracts and grant agreements, and its powers to inspect, regulate and investigate. Our revised actions aim to spell out more clearly how we will use these levers to accelerate action.

Resources

The Minister for Social Justice has agreed to invest in and set up a Race Disparity Evidence Unit alongside an Equality Data Unit to improve quantitative and qualitative data on seldom‑heard groups in Wales.

Race Disparity Evidence Unit will offer targeted resource to support improvements to evidence on ethnicity. In 2022 the development of the Race Evidence Programme will begin, which will include identification of the top priorities in this area.

In the short‑term, needs will be met through the Race Disparity Evidence Unit delivering ad‑hoc evidence reviews and analysis using currently available evidence sources. In the longer‑term the Race Disparity Evidence Unit will have a vital role in influencing and improving a range of longer‑term solutions to evidence (as exampled in the Strategic Performance indicators section). Improvements across these areas could feed into longer‑term measurable performance indicators for this plan.

The Welsh Government are demonstrating their priority and commitment to this work by funding a central Anti‑racist plan team of officials who will lead the implementation. The team will work with both different policy officials leading on the actions outlined in section B and also with the leaders at different levels in the ethnic minority and other communities. Resources to support the Accountability Group will also be made available.

The Minister for Social Justice has agreed to implement a Race Disparity Evidence Unit alongside an Equality Data Unit to improve quantitative, qualitative, and lived experience data on seldom‑heard groups in Wales. The Race Disparity Evidence Unit will offer targeted resource to support improvements to evidence on ethnicity. In 2022 the development of the Race Evidence Programme will begin, which will include identification of the top priorities in this area.

We would like to thank the following for helping us to produce this plan. Every individual and group has provided evidence and insight that has made this plan what it is.

• The members of the Steering Group.
• The members of the Wales Race Forum, and also the many Black, Asian and Minority Ethnic individuals and organisations who helped to collect and collate the contributions from the wider community. Their efforts helped to bring us new voices, which greatly informed our work.
• The COVID‑19 Group Health Advisory Group and its Socio‑economic and Risk Assessment Sub‑groups. These produced a series of recommendations, many of which have been incorporated into the plan.
• The Cynefin and Monuments Advisory groups, The Black, Asian and Minority Ethnic Communities, Contributions and Cynefin in the New Curriculum Working Group, published two reports highlighting the need for more high‑quality learning resources, involving more positive representations, and detailing the contributions, of Black, Asian, and Minority Ethnic groups in schools in Wales. The Welsh Government accepted the findings in their entirety.
• The ‘community mentors’ who brought to our attention their individual and their communities’ lived experiences in specific policy areas and as feedback on the plan from their communities.
• The leaders and participants in our ‘community‑led dialogues’ with ethnic minority community groups and forums.
• The Trade Unions and the Wales TUC for working with us in social partnership, adhering to the important principles of co‑operation, respect and trust.
• The participants in our policy events, where we brought together partners from specific policy fields, to share evidence and develop potential actions.
• The Wales Centre for Public Policy and those who contributed to the rapid reviews of existing evidence conducted by the Centre.
• Those from the Ethnic Minorities and Support Youth Team Wales who provided invaluable help and facilitation at our ‘vision‑setting’ events.
• Those who gifted their time to participate in the various vision‑setting events and evidence‑ gathering phases of this work.
• Those experts, from across the UK, working in the field of anti‑racism who gave generously of their advice at short notice.
• Race Equality First for their collation and analysis for the consultation responses.
• We would also like to thank the team of officials and the policy leads who have been exceptional in managing the entire process leading to the development of this plan.

Rt. Hon. Mark Drakeford MS, First Minister of Wales

Jane Hutt MS, Minister for Social Justice

Professor Emmanuel Ogbonna, Cardiff University

Dr Andrew Goodall, Permanent Secretary, Welsh Government