Equality and Diversity Policy

1. Policy Statement
Riviera Housing Trust acknowledges that in society certain groups and individuals are unfairly and unlawfully discriminated against. The Trust is committed to helping redress the effects of unfair discrimination and disadvantage and to ensuring that equality of opportunity and diversity become integral features of all its activities. The Trust will always ensure that it does not discriminate unlawfully and has already implemented an Equal Opportunities Policy which states:

"No person or group which applies to us for employment, accommodation, services from or contracts with us will be treated less favourably than another person or group or discriminated against on the grounds of gender, marital status, being a lesbian or gay man, age, religious beliefs, HIV status, disability (covering sensory and physical disabilities, learning difficulties and mental health status) and race, colour, nationality or national or ethnic origin."

The purpose of this policy statement is to set out Riviera Housing Trust's commitment to eliminating discrimination from all aspects of its work and to outline policy priorities. Detailed guidance and procedures to be followed to achieve the policy objectives are set out in the separate Code of Practice, which is available on request.

2. Scope of the policy
The Diversity Policy applies to the following areas:

  • Provision of housing and related services.

  • Staff recruitment, employment and training.

  • Housing development & maintenance, including the selection and employment of contractors and consultants.

  • General procurement of goods and services.

  • Governance, including shareholders and the Board of Management.

3. Policy objectives
The objective of the policy is to eliminate unfair discrimination and, where appropriate, take positive action to redress the effects of discrimination in relation to:

  • Access to RHT homes, quality of accommodation offered to people in need and provision of management, maintenance and other related services to all tenants and leaseholders. This includes the protection of tenants' rights in relation to racial and other forms of harassment. 

  • Recruitment and selection procedures, and ensuring equality of opportunity for all job applicants and prospective applicants.

  • Staff management and support, and provision of training and development opportunities on an equitable basis so all employees are treated fairly on the basis of their relevant merits and abilities.  This includes the protection of the rights of staff in relation to racial and other forms of harassment.

  • The design, development and maintenance of RHT's housing, and the selection, employment and practices of its development and maintenance contractors and consultants.

  • Opportunities for individuals to become shareholders and Board Members.

  • The selection, employment and practices of RHT's other general suppliers, contractors and consultants.

Riviera Housing Trust recognises that the achievement of the above objectives will require changes to current practice and is committed to providing the necessary training and support to enable the Board of Management and the staff team to understand and meet their responsibilities under the policy.

The relevant statutory requirements are contained in:

  • Equal Pay Act 1970

  • Rehabilitation of Offenders Act 1974

  • Sex Discrimination Act 1975

  • Race Relations Act 1976

  • Disability Discrimination Act 1995.

  • Protection From Harassment Act 1997.

  • Human Rights Act 1998

  • Race Relations ( Amendment ) Act 2000

  • The Employment Equality (Sexual Orientation) Regulations 2003

  • The Employment Equality (Religion or Belief) Regulations 2003

Riviera Housing Trust will abide by these Acts.

The Trust will also comply with the requirements of:

  • The Housing Corporation's Regulatory Code and Guidance relating to race equality and equal opportunities.

  • The Race Equality Code of Practice for Housing Associations.

  • The CRE Codes of Practice in Rented Housing and Employment.

  • The Equal Opportunities Commission Code of Practice for Employment.

4. Target groups
The following groups are more likely to experience discrimination and disadvantage than others and therefore, the policy objectives focus on them to varying degrees:

  • Black and minority ethnic groups.

  • Women.

  • People with disabilities, including mental illness.

  • Lesbians and gay men.

5. Race and cultural diversity targets
Specifically in relation to black and minority ethnic people, and in line with the HC Regulatory Code and Guidance, the Code of Practice incorporates targets in the following areas:

  • Lettings.

  • Tenant satisfaction.

  • Dealing effectively with racial harassment.

  • Governing body membership.

  • Staffing.

  • Representation in Tenants forums.

  • Employment performance of suppliers, contractors and consultants.  

6. Responsibility for implementation
Riviera Housing Trust's Board, having formally adopted the Equalities and Diversity Policy, accepts responsibility for its implementation and for monitoring its effectiveness, and will ensure that as part of implementation that an Equalities Working Group, chaired by the Managing Director, and with Board member and tenant representation, will monitor and continually develop the Policy in line with best practice.

Day-to-day responsibility for implementation lies with the Managing Director, and the other members of the Senior Management Team. The Company Secretary will act as the designated equal opportunities officer and will, along with the Neighbourhood Managers, be designated to deal with harassment cases and reporting. All these staff have a responsibility to undertake stated duties and report to the Board, via the Managing Director. Besides the statutory duty not to discriminate, all staff have a responsibility to ensure the positive application of this policy.

The success of any policy, however, depends not only on the degree of commitment of all employees, but also on the extent to which the Managing Director and other Managers turn commitment into action. Together with the Managing Director, the Senior Management Team has a particular duty to ensure that the requirements of this policy for all the areas of work under its control, in respect of the target groups prioritised above, are planned and met.


The policy will be implemented by:

  • Operating the procedures and practices outlined in the separate RHT Code of Practice.

  • Annual review of current practices and identification of weaknesses in
    procedures, or where practicable ongoing review and improvement.

  • Devising and implementing new procedures for monitoring equal opportunities in various functions, usually as part of the annual review, but earlier if practicable and sensible.

  • Establishing equality targets and regular performance reviews.

  • Subject to internal discussion and agreement, and compliance with relevant legislation, devising and implementing positive action programmes where appropriate.

  • Monitoring progress and reporting to the Board via the Equalities Working Group at regular intervals and periodically reviewing the policy itself.

Breaches of this, as of all other Riviera Housing Trust policies, may be the subject of disciplinary procedures.

7. Monitoring the Equalities and Diversity Policy and implementation programme
The Board has responsibility for monitoring progress via the Equalities Working Group. Regular reviews will be undertaken to monitor:

  • Performance against targets.

  • Effectiveness of procedures.

  • Feedback on how the policy is operating; and

  • Progress of implementation programmes (including positive action) with respect to agreed timetables.

The Equalities Working Group will report regularly and make recommendations to the Board as necessary. Minutes etc. will be published and circulated with Board reports and also circulated to staff via Managers.  

Subject to Board approval, the Board should delegate authority to the Equalities Working Group for the review and approval of the Equalities and Diversity Policy and Code of Practice, and other strategies, and action plans, advising the Board of any material changes and budgetary implications.

Monitoring is important to test whether the policy and procedures are working, and to enable the Trust to take remedial action if they are not. Monitoring methods and reasons for specific monitoring are explained in more detail in the Code of Practice.

8. Resources
Riviera Housing Trust will allocate appropriate resources, to ensure full and effective implementation of this policy.

The Customer Services Manager will co-ordinate the collection of monitoring information, and will liaise closely with the Neighbourhood Services Manager to ensure that all information related to harassment are properly recorded and action taken. Heads of department, managers and other staff, have other responsibilities set out under the policy. These officers will undertake key roles in implementing the policy. The importance of their roles, and the priority Riviera Housing Trust places on this work will be recognised and they will be given any necessary support, ongoing training, guidance and powers necessary to enable them carry out this function of their role. Difficulties and obstacles encountered in doing their jobs should be drawn to the attention of the respective head of department or the Managing Director to ensure they are resolved.

9. Future action
The Managing Director will establish action plan targets to:

  • Co-ordinate, run and service the Equalities Working Group.

  • Set out the responsibilities of heads of department for implementing the policy.

  • Set out the responsibilities of the Customer Services Manager.

  • Oversee and manage the work of the heads of department and the Customer Services Manager in implementing the policy.

  • Plan annual and other reviews identified as necessary during the year.