CEO’s Introduction
I am pleased to introduce our latest diversity, inclusion and wellbeing report. Since I joined as interim Chief Executive and Chief Ombudsman in May 2021, it has been clear to me that diversity, inclusion and wellbeing are core to the culture and values of the Financial Ombudsman Service, and are supported through many inspirational and meaningful initiatives.
The Periodic Review, undertaken by independent advisers and published in December 2021, recognised our good work in this area. It found that:
- Our organisation ‘continues to be open and inclusive to all customers.’
- ‘The values of openness, inclusivity and fairness were apparent at all levels.’
- We have made ‘commendable efforts’ and ‘obvious progress at creating a diverse workforce’ throughout ‘every level of the organisation.’
I want to ensure that we keep up this work and go even further in our ambitions. We have been recognised this year by the Disability Confident scheme, and the London Mayor’s Good Work Standard, a scheme for high employment standards in London, and am proud to say we have received the highest accreditation in both schemes.
I believe passionately in allowing everyone a fair chance to progress, and I am pleased that we are improving our diverse approach to recruitment. Our gender and ethnicity pay gaps have continued to narrow over the past year, too.
But we must not get complacent. While we may be moving in the right direction, there is more to do, especially on our ethnicity pay gap. This year will see our organisation change and improve. We will protect the progress we have made by keeping diversity, inclusion and wellbeing at the heart of the Financial Ombudsman Service as it evolves.
It is also important to me that diversity and inclusion encompass all aspects of our work. We have stepped up our inclusion ambitions, and inclusion is now part of everyone’s objectives.
We must continue to reflect the communities we serve, to create a workplace where every person belongs and can be their best, and where every idea can be voiced and every voice be heard. This includes striving to achieve cognitive diversity in decision-making, to avoid ‘groupthink’ – and ensuring neurodiverse voices are part of our way of life.
But actions speak louder than words, which is why we work hard to provide our people with the training, knowledge and tools to practise inclusion, both in the way we work with one another and in how we work for every consumer, whatever their background.
An emphasis on wellbeing has been crucial in the face of the challenges presented by the pandemic. As part of our hybrid working model, many of our people continue to spend some time working from home. We have sought to ensure they are able to stay resilient and well, by developing resources that they can use wherever they work.
In addition to measures in place at the office, webinars, virtual gym classes, and flu vouchers have all helped our people maintain their mental and physical health at home during these difficult times, so they can continue to provide an outstanding service to our customers.
I want to congratulate and thank our people for their commitment over the past year, and I look forward to working with them, as well as with colleagues from across the regulatory ecosystem, to continue to build on our progress.
Nausicaa Delfas
Interim Chief Executive and Chief Ombudsman
February 2022
- Women make up 55% of our workforce, 57% of our board and executive, and 46% of our senior managers
- 35% of our people are from ethnic minority backgrounds, 29% of our board and executive, and 15% of our senior managers
- 50% – our target for women in senior management
- 20% – our target for senior managers from ethnic minority backgrounds
Delivering on our action plan
We want to make sure our organisation is truly inclusive and diverse. This is important for attracting and retaining the best talent, and creating a working environment in which everyone can thrive.
It is so our people can be themselves, and feel confident that differences are embraced, respected and celebrated. A diversity of voices stimulates innovation and encourages better judgements and decisions.
As a truly diverse and inclusive organisation, we can better reflect the communities we serve, understand the needs of people who rely on us, and deliver better outcomes for consumers, businesses and the financial services sector as a whole.
Since 2016, we have brought this work together under our diversity, inclusion and wellbeing action plan, and set ourselves ambitious diversity targets, including our gender and ethnicity pay gaps.
We work with partner organisations and accreditation schemes, with whom we share best practice and set some of our goals. These include HM Treasury’s Women in Finance Charter, the Mayor of London’s Good Work Standard, Stonewall’s Workplace Equality Index, the Department for Work and Pensions Disability Confident scheme, and Working Families.
Our action plan is organised around the five pillars below. Here we discuss our progress in each of these areas and assess the impact this has on our strategic measures, pay gaps and other commitments. We celebrate our achievements so far, and look ahead to what we are doing that will take us further.
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We want to maintain inclusive leadership that fosters a sense of trust and belonging, and seeks out wide-ranging viewpoints to improve the exchange of ideas and the quality of decision-making.
Our focus over the past year has been to invest in senior management skills, to embed an inclusive culture through a number of initiatives. We ran quarterly action sessions with senior managers to support these goals, and to provide a platform for constructive conversation and fruitful collaboration. Senior managers were encouraged to lead change – for instance, by introducing and facilitating discussion about the roll-out of inclusion objectives to all staff.
We are helping our leaders to recognise and counteract biases, and create the supportive environments that allow team members to realise their full potential, whatever their background.
The number of our Board members from an ethnic minority has increased from one to four, which is a better reflection of the diversity of the Financial Ombudsman Service as a whole. We have been working work with recruitment firms that excel in diverse hiring to fill some of our most senior roles.
Our award-winning staff ethnicity network, Embrace, led the development of an anti-racism and active allyship programme, alongside HR and Business in the Community, a member association. This has helped our leaders to make a positive difference to influence how staff feel and act at work, building on a foundation of mutual understanding and respect.
Some feedback from our attendees:
The allyship programme has been brilliant. The sessions provided a safe, open space which allowed for much discussion. I left with a greater understanding of my own privilege – and tools to help me be an active ally, including ways of ensuring diversity of voice in decision-making.
I’m so pleased I’m am part of it. It has been really thought-provoking.
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As well as providing everyday support to diverse groups within our workforce, our employee-led networks help us understand what really matters to our staff. Following changes in some senior posts, we realigned our executive and senior sponsors with our networks. This allowed us to maintain the link between the networks and senior decision-makers, while re-energising them to help drive forward our inclusion and wellbeing strategy.
Our employee networks have been raising awareness and educating our people through lunchtime events during South Asian Heritage Month, Black History Month, Holocaust Remembrance Day and Work/Life Balance Week. We also held an event where colleagues who are gender non-binary shared their insights and experiences with colleagues, to help broaden understanding.
The neurodiversity and cancer support groups, led by our disability and long-term health conditions network Enable, ran events and activities, creating a space for colleagues to share experiences and find support.
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Anyone applying for a role deserves a fair chance of selection on their own merits. Academic studies have shown that implicit biases – such as names, addresses and educational establishments – can unfairly influence candidates’ chances of selection. Having trialled it, we are introducing anonymous applications for all our vacancies, following the successful implementation of our new HR system, Workday.
We are working to ensure we have a diverse demographic makeup in our applicant pool, including through a new contract with a job board platform targeting underrepresented groups.
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We introduced an improved application structure for colleagues seeking to join our casework practice groups. Our practice groups focus on developing knowledge and skills in specific casework areas to enhance career opportunities and improve consumer outcomes. Their makeup already reflects our diversity as an organisation. To maintain this, we worked to clarify and standardise the application process, with defined roles for every group, ensuring that appointments are fair and objective.
In 2021, we also anonymised applications for our development programme for casework colleagues.
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We continue to offer comprehensive wellbeing resources to our people, with a focus on mental, physical and financial health. We ran financial wellbeing sessions with the organisation, Better With Money, receiving excellent feedback from employees. The ‘Mental health for leaders’ programme and positive psychology webinars have been well attended, covering a number of topics, including ‘Resilience in change’. Our 38 mental health first aiders continue to support our people remotely and in person. We offered free flu jab vouchers and free virtual and studio gym classes to help our employees stay well and at work.
Looking ahead
Although we can be proud of our achievements to date, we know that there’s always more to do. By planning ahead, monitoring progress, and sharing ideas, we can identify new ways to improve.
We are expanding our training to include updated modules on inclusion and wellbeing, which will enhance colleagues’ knowledge of inclusive culture, our values, and behaviours.
We are also completing the Working Families standard for the third time since 2018 and continue to strive to attain a place on the Top 30 Employers for Working Families list. The standard measures all aspects of flexible working and work/life policies and practice, and compares employers from across the public, private, and third sectors.
As we fully adopt hybrid working in 2022, we will continue to consider its implications for our inclusion and wellbeing action plan and strategy.
Pay and representation
Our pay gap data informs our diversity and inclusion strategy, and helps us to drive positive change. We have a legal duty to publish our gender pay gap data, but we freely choose to publish our ethnicity pay gap data to provide a higher level of transparency and to demonstrate our commitment to targeted action to improve representation across the organisation.
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The median is the midpoint value in a given data range. The mean is the sum of all the values, divided by how many values there are.
To measure our gender and ethnicity pay gaps, we compare the median and mean hourly earnings of different groups – men and women for the gender pay gap, and white and ethnic minority employees for the ethnicity pay gap. The difference between the two groups is given as a percentage.
The median is usually taken to be a more representative measure of pay gaps than the mean, as it is less affected than the mean by a small number of very large or very small values.
Pay gaps between groups are usually the result of differences in representation at senior and higher-paying levels.
‘Ethnic minority’ (EM) replaces Black, Asian and minority ethnic (BAME) in this year’s report. The definition of EM is the same as BAME, denoting ethnic minority staff and does not include those who did not disclose an ethnicity.
Our gender and ethnicity pay gap snapshots are taken on 5 April each year. For the purposes of this analysis, we have not included interim appointments among our staff figures.
We have made changes to what we categorise as our senior manager roles. This has had some modest effects on comparisons with previous years. The breakdown of our organisation by income quartile is unaffected.
The ethnicity pay gap is based on data from those who have disclosed this information, which is why the overall bonus figure, for example, is different from that given in the gender pay gap data.
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Our 2021 median gender pay gap has reduced to 5.5% (6.2% in 2020). Our mean pay gap, at 6.4%, has grown, though it is still below where it was in 2019 (6.6%).
Our median pay gap has fallen because more women have progressed beyond, or joined above the Financial Ombudsman’s salary mid-point this year. At the same time, we have recruited some women in our lowest-paid positions, and lost some of our highest-paid women, increasing the mean pay gap.
Our mean bonus pay gap reduced to 1.7% (3.5% in 2020), and our median bonus pay gap remains 0%.
Gender pay gap (as at 5 April 2021)
Pay 2021 2020 Difference in median pay 5.5% 6.2% Difference in mean pay 6.4% 5.9% Difference in median bonus pay 0.0% 0.0% Difference in mean bonus pay 1.7% 3.5% Bonus Male Female Overall 73.8% 75.4% 74.7% Pay quartile distribution Male Female 2021 2020 2021 2020 Upper quartile 49.0% 49.3% 51.0% 50.7% Upper middle quartile 48.2% 47.2% 51.8% 52.8% Lower middle quartile 40.4% 39.3% 59.6% 60.7% Lower quartile 40.6% 42.0% 59.4% 58.0% Gender makeup of the organisation Male Female 44.6% 55.4% -
Our median, mean and bonus ethnicity pay gaps have all fallen for the second successive year. Our median gap fell to 14.9% in 2021 (16.1% in 2020) and our mean gap fell to 22.3% (24.5% in 2020).
Pay 2021 2020 Difference in median pay 14.9% 16.1% Difference in mean pay 22.3% 24.5% Bonus 2021 2020 Difference in median bonus pay 0.0% 0.0% Difference in mean bonus pay 10.1% 10.3% Pay quartile distribution White EM Upper quartile 81.3% 18.8% Upper middle quartile 61.9% 38.1% Lower middle quartile 46.9% 53.1% Lower quartile 52.0% 48.0% Whole organisation 60.5% 39.5% We chose to publish our ethnicity pay gap for the first time last year (although the data was a snapshot of 5 April 2020). We are continuing to publish it, reflecting our commitment to transparency and to a better understanding of the action we need to take to make positive change.
Last year, we found that length of service correlated with higher pay and our longest-serving members of staff were predominantly white. This is a reflection of the fact that in the past, the ethnic composition of the organisation was less diverse than it is now.
When we grew to meet the heavy demands that payment protection insurance (PPI) put on our organisation, we became significantly more ethnically diverse. We are pleased that the winding down of our PPI operations has not resulted in us reverting to pre-PPI levels of diversity, although this year’s data reflects a 2% drop in the total proportion of declared ethnic minority staff.
We took steps to retain colleagues by finding ways to transfer the skills they had developed working on PPI, and by offering opportunities where possible in other parts of the organisation.
As this more ethnically diverse cohort rises through the organisation, we are monitoring career progression and appraisal ratings to identify ways to close our ethnicity pay gap further. Over recent years, we have found that ethnic minority staff have progressed at a higher rate relative to their population sizes than white colleagues. Meanwhile, white staff retain a small lead in annual appraisal ratings, which are linked to bonus payments and, therefore, to the mean bonus pay gap.
We have a number of interventions underway as part of our action plan. We are committed to:
- building on our understanding of the relationship between performance and appraisal ratings, and ethnicity
- a 20% target for ethnic minority representation among our senior leaders
- supporting our leaders to drive forward and embed a truly inclusive culture
- supporting equity in opportunity to grow and develop.
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Our gender balance in December 2021, compared with December 2020
Position Female Male 2021 2020 2021 2020 Our senior managers 46% 44% 54% 56% Our board and executive teams 57% 57% 43% 43% Both groups together 47% 46% 53% 54% We are committed to achieving gender balance at all levels. Female representation on our board and executive teams remains good at 57% (given the historically low rates within the sector), and we are continuing to make progress towards our target of 50% female representation in our senior roles by December 2023, reflecting the gender balance of the UK as a whole.
We remain signatories to HM Treasury’s Women in Finance Charter, which over 350 organisations have signed, committing to improving gender diversity at senior levels of the financial services sector.
New schemes and accreditations
We joined the London Mayor's Good Work Standard in 2020, and are proud to have been awarded the Excellence level, the highest accreditation available.
The scheme is a benchmark for high employment standards, covering fair pay and conditions, wellbeing, skills, training and progression, diversity and recruitment, and representation at work. As such, it ties in closely with the goals we have set ourselves in our action plan.
The Good Work Standard plays a key role in tackling poverty and inequality in London. We are grateful to have had the opportunity to play our part, by paying the London Living Wage, enhancing apprentice salaries, pursuing greater diversity, achieving the highest standards in wellbeing and training, and ensuring our people have a voice in the workplace.
We are similarly proud to be a Disability Confident Leader level 3 employer, the highest accreditation. Led by the Department for Work and Pensions, the scheme helps us successfully employ, retain and make the most of the valuable skills, talents and experiences that disabled people and those with long-term health conditions can bring to the workplace. Our staff network, Enable, helped drive this accreditation.
We have signed the Charter for Employers Positive about Mental Health, making us a certified Mindful Employer, and following an event on the menopause we held in early 2022, have signed the Menopause Workplace Pledge.
This year we also attained a gold award in Stonewall’s Workplace Equality Index for our progress on LGBT inclusion in the workplace.
Campaigns and casework insight
Our approach to diversity, inclusion and wellbeing can help us serve our customers better and reach fairer outcomes in the complaints we resolve. We are often asked to consider whether a business unfairly disadvantaged a customer, perhaps in the context of protected characteristics such as age, disability, or race. The diverse and inclusive nature of our organisation enhances the service we deliver. The broader the range of experiences and perspectives staff have and feel comfortable sharing, the greater is our collective capacity to understand and empathise with the people who come to us for help.
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We receive complaints where customers tell us they have been treated differently or unfairly by a financial business because of who they are. Complaints involving issues of discrimination can be complex, challenging and involve vulnerable customers.
In June 2021, we launched a campaign internally to raise awareness of how issues of discrimination can present in complaints referred to us. We ran activities to help case handlers identify these types of complaints, to tackle the issues confidently, and deliver fair answers. We wanted them to feel supported and able to deliver good customer service – showing that, as an organisation, we listen, understand, care about the issues and resolve cases fairly.
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Our Supporting Our Customers practice group advises casework colleagues on areas including complaints involving vulnerable customers. It hosted an interactive seminar in order to get a deep and practical understanding of all aspects of challenging cases and in April, we shared information on our website about the types of complaints we see involving domestic and economic abuse, with case studies to show how we’ve resolved complaints referred to us.
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We also ran training this year to continue to embed our Unreasonable Behaviour policy, so that case handlers feel supported and empowered when handling unreasonable, abusive or discriminatory behaviour when doing their job.
