Tackling workplace racism: no more tick boxes

Recommendation 3 of the Mann Review states that “in considering their work to develop robust, evidence-based workforce race equality standard (WRES) action plans, with specific, measurable targets, trusts should ensure they monitor progress against WRES action, applying the ‘explain or reform’ principles for any persistent inequalities.” 

This is absolutely correct. The problem is that NHS employers have known for over a decade that is what they need to do and have known for almost as long what “evidence-based” Action Plans for most of these metrics should look like.

Unfortunately, NHS Boards (national, regional, ICB and Trust) have rarely asked whether there was an evidence base for the Action Plans they dutifully published every year. Few Boards asked why they should approve an Action Plan that looked remarkably similar to the one they approved the previous year but which made little or no difference to the experience of Black and Minority Ethnic staff in the organisation.

Part of the reason for this was that many Boards simply didn’t prioritise the issue. Another reason was that too many Boards even struggled to have honest conversations about racism even when it was obvious it was a significant issue impacting patient care and staff well-being.  Too often courage was in short supply. Another reason was the dismal failure by NHS England to identify and disseminate evidence-based interventions on race discrimination, never mind model the behaviours they expected of others.

But there is another crucial reason. Methodology. Even those organisations that did want to make progress were reliant on an approach that was bound to fail. The National Health Service has largely relied on a human resources trilogy of policies, procedures and training to improve organisational culture including race discrimination.  This approach – methodological individualism – purports to enable decision makers to make steady improvement in employment relations whilst simultaneously supporting individual staff who sought fair and just outcomes to challenge outcomes or use those processes to challenge outcomes or seek just ones. But evidence from research findings on four interventions using this approach —disciplinary action, bullying, whistleblowing and recruitment and career progression found that this approach, in isolation, was never likely to be effective. https://bmjleader.bmj.com/content/7/4/314

Establishing cause and effect in human behaviour and specifically in respect of “what works” when tackling discrimination is not straightforward. Whilst randomised controlled studies and controlled longitudinal studies would be the most reliable evidence, in this field we have to rely on meta-analyses, systematic reviews, cross sectional studies and case studies whose quality will vary.  It is difficult to conclusively prove causality in this field, though it is possible to do experiments that come fairly close e.g. monitor the impact of changing names on job applications by ethnicity. Where possible meta-analyses and systematic reviews are more reliable. Alongside these case studies, lab experiments, expert opinion and grey literature may help in signposting interventions and methodologies that are more likely to be effective.

There is an important caveat. Any findings cannot be lifted and implemented without considering the context in which the evidence emerged and in which it is intended it is used. That does not mean what is reported is not relevant or useful but means caution against simply “lifting” findings is necessary. The different workplace “climate”, staff engagement, and use of improvement methodology must be considered.  See this for a discussion: https://cebma.org/assets/Uploads/Evidence-Based-Practice-The-Basic-Principles.pdf

There are other considerations. Let’s take covert racism first since it is the dominant form of NHS racism.

Firstly, many aspects of Equality, Diversity and Inclusion work focus on compliance rather than improvement. This largely drives a focus on the risks to the employer not the opportunities to use that arise from tackling discrimination promoting inclusion and equality to improve patient care and staff experience. https://www.rogerkline.co.uk/post/not-an-optional-extra-the-price-of-not-tackling-race-discrimination-in-the-nhs

Secondly, there has been a widespread avoidance of creating workplace cultures where leaders at all levels feel confident about discussing race, are able to identify racism and take personal responsibility for modelling the behaviours they expect of others. Much effort has gone into training that has little or no evidence base. The proposal in the Mann Review to “sheep dip” all 1.5 million NHS staff in a short on line mandatory training on antisemitism and racism is a good example. It is pointless. Most racism is deeply embedded, often not visible, often not intended. Challenge is frequently met with avoidance and denial or seen as “too difficult”.

Thirdly, there has been a failure to be proactive and preventative – a public health approach to race discrimination – indeed to all forms of race discrimination. Clinical leaders at all levels do not wait for poor practice or clinical risks to surface. They are (or should be) constantly problem seeking, using data of all kinds (including patient and staff experience) to identify where and how risks might occur. HR and OD teams should be using the requirements on employers to risk assess for racial harassment (and other forms of harassment) rather than playing whack-a-mole as each new compliant surfaces. https://www.equalityhumanrights.com/guidance/sexual-harassment-and-harassment-work-technical-guidance If not, why not?

Finally, I find it astonishing that most Trusts are still not applying evidence-based methodologies, for example, to address discrimination (of any kind) in recruitment and career progression, on speaking up, on bullying and harassment. The only significant aspect of NHS employment relations where evidence-based interventions have been widely used is in disciplinary action where numbers of disciplinary cases have more than halved in the last seven years and where the relative likelihood of BME staff entering the disciplinary process has also been radically reduced in the same period from 1.54 to 1.11. Yet even here, there has been zero national leadership. Data on the other WRES metrics is largely unchanging or worse as this years Workforce Race Equality Data shows. https://www.england.nhs.uk/publication/workforce-race-equality-standard-2025-data-analysis-report-for-nhs-trusts/ If employers want to know how, for example, to implement evidence-based strategies of recruitment and career progression, they could start here: https://www.england.nhs.uk/east-of-england/wp-content/uploads/sites/47/2021/10/NHSE-Recruitment-Research-Document-FINAL-2.2.pdf

We have to abandon, immediately, the reliance on methodological individualism – the primary reliance on policies procedures and training,. There is more chance of pigs flying then this approach working. Instead, we should emphasise accountability, emphasising debiasing processes rather than relying on debiasing people, being proactive, emphasising improvement not just compliance rather than primarily relying on debiasing people. And led by leaders who understand this issue, make it a priority and lead by example.

If we want to tackle the overt racism Lord Mann overwhelmingly focuses on, then The new Worker Protection (Amendment of Equality Act 2010) Act 2023 provides the central means of doing so – risk assessing in order to be preventative and proactive, alongside setting clear behavioural standards modelled and supported by leaders with consequences for all if they are breached. Those behavioural standards should embody respect, compassion, inclusion and psychological safety since all are evidenced contributors to safer care and healthier working environment. That means support for staff but it also means consequences for race discrimination, harassment, bullying, incivility and for anyone who prevents staff raising concerns on these issues, or victimises them for doing so.

Understanding all this, making it a personal priority, and modelling the behaviours expected of others has to become a precondition of all senior appointments and should become part of all managerial appointments. The crisis in maternity care alone shows why – racism has gone largely unchallenged for decades,

Whatever his motives, much of Lord Mann’s report will soon be wrapping fish and chips. But his call for Trusts “to develop robust, evidence-based workforce race equality standard (WRES) action plan” is spot on and should be acted on. 

We are about to have a new Prime Minister at a time when no one can pretend tackling racism is not imperative..  If he (and we) cannot prioritise serious work on discrimination now, rather than the performative ones that have dominated the landscape, then we know Ministers are simply no more serious than their predecessors

Whatever his motives, much of Lord Mann’s report will soon be wrapping fish and chips. But his call for Trusts “to develop robust, evidence-based workforce race equality standard (WRES) action plan” is spot on and should be acted on.