Revising the code of practice on ethical employment in supply chains: equality impact assessment
An equality impact assessment for revising the code of practice on ethical employment in supply chains.
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Promoting equality
The revised Code is expected to promote equality by strengthening organisational responsibilities to prevent discrimination, harassment and victimisation, and by encouraging suppliers to actively improve their equality, diversity and inclusion (EDI) practices. This aligns with the general duties under the Equality Act 2010 by advancing equality of opportunity, fostering good relations, and eliminating unlawful discrimination. Clearer expectations around fair work, worker voice, equal treatment, safer working environments and the Real Living Wage also help reduce inequalities that disproportionately affect people with protected characteristics and those living in low‑income households. The Code aligns with, and upholds the principles of, the Welsh’s Government’s Equality Action Plans including the Disabled People’s Rights Plan, the Anti-Racist Wales Action Plan and the LGBTQ+ Action Plan.
No negative impacts for protected groups have been identified. The non‑mandatory nature of supplier sign‑up, combined with flexible and proportionate implementation, helps mitigate this risk. The forthcoming public consultation will provide an opportunity to test feasibility, proportionality and accessibility, ensuring the needs of minority groups and those with additional barriers are fully understood.
People who share protected characteristics may face barriers linked to discrimination, low pay, insecure work, unsafe conditions or lack of voice. The revised Code directly addresses these barriers by requiring signatory organisations to embed equal opportunities into recruitment and employment practices, respond robustly to harassment (including sexual harassment), promote inclusive workplaces, and uphold trade union access and worker representation. Strengthened commitments on health and safety and remediation of harms further reduce risks disproportionately experienced by marginalised groups.
Record of impacts by protected characteristic
| Protected characteristic or group | What are the positive or negative impacts of the proposal? | Reasons for your decision (including evidence) | How will you mitigate Impacts?
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|---|---|---|---|
| Age | Potential positive impact | The revised Code promotes fair work, job security, safer workplaces and improved employment standards. These benefits support people of all ages. No negative impacts identified. | No negative impacts are expected. Fair work guidance, EDI expectations and accessible consultation materials will ensure the needs of different age groups are considered. |
| Disability | Positive impact | The revised Code commits suppliers to demonstrate strong EDI policies and inclusive employment practices, which can potentially reduce barriers experienced by disabled people. No negative impacts identified. | No Negative impacts are expected. We will monitor this through continued engagement with disability groups during consultation and emphasis on accessible formats and reasonable adjustments within procurement and employment practices. |
| Gender Reassignment | Potential positive impact | Strengthened expectations on anti-discrimination and harassment protections potentially may support trans and non-binary workers, who could face a higher risk of workplace discrimination. | Ongoing monitoring of supplier EDI commitments, consultation will test whether additional guidance is required. |
| Pregnancy and maternity | Potential positive impact | Stronger commitments on equality, job security and fair treatment to support workers who may be vulnerable to discrimination during pregnancy or on maternity. | No negative impacts are expected. Monitoring through contract management and supplier reporting will ensure that guidance highlights maternity related rights. |
| Race | Potential positive impact | The Code’s focus on modern slavery, human rights, anti-discrimination and responsible recruitment supports workers who are a higher risk of exploitation. | No negative impacts are expected. Engagement with community and race equality organisations, targeted support for high-risk supply chains.
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| Religion, belief and non-belief | Potential positive impact | The revise Code includes expectations for inclusive employment conditions and actions against harassment, supporting workers of all faith backgrounds. | No negative impacts are expected. Ensure supplier policies address religious inclusion.
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| Sex / Gender | Potential positive impact | The revised Code includes commitments on fair pay, living wage, safer workplaces and tackling discrimination. | No negative impacts are expected. Mitigation through promotion of compliance with EDI monitoring highlighting sexual prevention requirements. |
| Sexual orientation (Lesbian, Gay and Bisexual) | Potential positive impact | The revised Code’s strengthened equality and anti-harassment expectations aims to reduce risks of discrimination. | No negative impacts are expected. Contract management and consultation feedback will help identify additional support needs.
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| Marriage and civil partnership | Potential positive impact | The revised Code requires equal treatment across employment practices. | No negative impacts are expected. Any mitigations are by promoting awareness of non-discriminatory requirements among suppliers. |
| Children and young people up to the age of 18 | No direct impact | Children benefit when caregivers have fair, stable, safe work and adequate income. The revised Code addresses exploitation and fair pay, which can potentially reduce child poverty. | No negative impacts are expected. Consultation will seek views which may result in strengthening the assessment.
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| Low-income households | Potential positive impact | The revised Code strengthens Real Living Wage commitments, job security protections and fair work.
| No negative impacts are expected. Any mitigations are by promoting the voluntary adoption of the code and supporting suppliers to implement Living Wage commitments. |
Human Rights and UN Conventions
| Human Rights | What are the positive or negative impacts of the proposal? | Reasons for your decision (including evidence) | How will you mitigate negative Impacts?
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|---|---|---|---|
| Positive impact | The revised Code strengthens expectations relevant to the Human Rights Act 1998, including: freedom from exploitation and servitude, rights to safe working conditions, non‑discrimination, fair treatment, and access to remedy. It aims to reduce risks of modern slavery and unsafe working conditions and supports the rights of vulnerable workers, including migrants and those in insecure work. No negative impacts identified. | No negative impacts are expected. On-going monitoring and post implementation review will ensure that if any human rights risks are identified, they are addressed as they emerge. |