Equality, Diversity & Inclusion

The 9 Protected Characteristics — Equality Act 2010 s.4

The Equality Act 2010 prohibits discrimination on the basis of nine protected characteristics. All nine apply to police officers and staff in their employment relationship, and most apply in service delivery to the public.

How discrimination is defined

Direct discrimination (EA 2010 s.13) is less favourable treatment because of a protected characteristic. Indirect discrimination (EA 2010 s.19) is a provision, criterion or practice that puts those sharing a characteristic at a particular disadvantage.

Harassment (EA 2010 s.26) and victimisation (EA 2010 s.27) are separate, specifically defined forms of unlawful conduct under the Act.

For disability, EA 2010 s.20 sets out the duty to make reasonable adjustments (three requirements); s.21 provides that a failure to comply with that duty is itself an act of discrimination.

Menopause Policy in Policing

Menopause can significantly affect operational capability. Forces have a duty under the Equality Act (disability and sex) to consider reasonable adjustments. The College of Policing has published guidance encouraging forces to have specific menopause policies.

Operational symptoms: hot flushes, fatigue, brain fog, anxiety, and sleep disruption can affect patrol, driving, firearms, and custody roles. Officers should not be penalised for symptoms before reasonable adjustments are explored.

Shift flexibility: adjusting shift patterns, reducing night shifts, or allowing more frequent rest breaks may be reasonable adjustments. Line managers should engage in documented conversation rather than assumption.

Uniform modifications: natural fibre uniform options, looser-fitting base layers, and access to cooling facilities may be reasonable. Forces should not require officers to remain in full kit in extreme heat without alternatives.

Temperature control: access to fans, cooler working environments, or the ability to work from cooler areas during acute symptoms. PPE modifications during perimenopause should be assessed individually.

Disclosure to supervisors: officers are not obliged to disclose. However, disclosure triggers a duty on the supervisor to consider adjustments. Supervisors must treat disclosures in confidence and must not record menopause as a performance issue without proper assessment.

Occupational Health support: OH referral can provide formal recommendations for adjustments, which carry more weight in management decision-making. Officers can self-refer in many forces. OH reports are confidential from line managers unless the officer consents.

Neurodiversity Awareness in Policing

Neurodivergent conditions including ADHD, autism spectrum conditions, dyslexia, dyspraxia, and dyscalculia are protected as disabilities under the Equality Act where they have a substantial long-term effect. A strengths-based approach recognises that neurodiverse officers often bring significant operational value.

ADHD in policing: officers with ADHD may excel in fast-paced operational environments but struggle with paperwork, long reports, and extended routine tasks. Reasonable adjustments may include task chunking, digital tools, extended time for written work, and body-doubling arrangements.

Autism spectrum conditions: officers with autism may bring exceptional attention to detail, pattern recognition, and rule adherence — highly valuable in investigation and intelligence roles. Adjustments may include clear communication expectations, structured briefings, and reduced sensory overload in custody environments.

Dyslexia: dyslexic officers may struggle with written reports, statement quality, and reading dense legislation. Adjustments include text-to-speech software, voice recording statements for later transcription, and additional time for written assessments. Dyslexia does not affect verbal communication or operational judgement.

Recognising neurodivergence in colleagues: be alert to colleagues who appear to struggle in ways not explained by attitude or ability — inconsistency, difficulty with sequential tasks, or social misunderstandings. Avoid labelling behaviour as poor performance before exploring neurodiversity with the individual and OH.

Strengths-based approach: the College of Policing promotes a strengths-based model. Forces should identify roles and tasks where neurodiverse officers excel and deploy them accordingly, rather than focusing solely on difficulties.

Access to Work scheme: a government (DWP) scheme that can fund specialist equipment (e.g. voice recognition software, ergonomic aids), workplace assessments, and support workers for neurodiverse officers and staff. Applications are made directly to DWP; this is a non-statutory support scheme, not an Equality Act provision.

Race Action Plan & Internal Culture

Baroness Casey's 2023 review of the Metropolitan Police identified institutional racism, misogyny, and homophobia as widespread. While focused on the Met, its findings have prompted national reflection and the NPCC Race Action Plan. Both are College of Policing / NPCC programme material, not legislation.

Casey Report (2023): the report found that the Met had failed Black Londoners both as a community and as employees. It identified discriminatory behaviours, disproportionate discipline of Black officers, and systemic failures in leadership accountability.

NPCC Race Action Plan: a national programme to increase BME officer representation at all ranks, address disproportionality in misconduct proceedings, improve stop and search data analysis, and create inclusive internal cultures. Forces are expected to publish local action plans.

Stop and search disproportionality: published Home Office statistics have consistently shown Black people being stopped and searched at several times the rate of white people. Forces must analyse s.60 CJPOA 1994 and PACE s.1 data by ethnicity. Where disproportionality is identified, forces must be able to account for it or take action to reduce it.

Internal discipline disproportionality: BME officers are significantly overrepresented in misconduct proceedings relative to their numbers. HMICFRS inspections include analysis of discipline data by ethnicity. Officers who believe they are facing discriminatory discipline should contact PFEW or a solicitor.

Bystander intervention: officers witnessing racist or discriminatory behaviour — including banter — have a professional duty to challenge it or report it. Failure to act may itself constitute a conduct matter. The Code of Ethics requires officers to report colleagues' wrongdoing.

LGBT+ in Policing

LGBT+ Police Network (LAGPA): the national network for LGBT+ officers and staff. Provides peer support, policy consultation, and visibility at Pride events. Individual forces typically have their own LGBT+ staff networks. This is a non-statutory support network.

Transitioning at work: officers undergoing gender reassignment are entitled to work in their preferred gender during and after transition. Forces should develop a transition plan with the officer, covering uniform, facilities, records update, and communication to colleagues. A full Gender Recognition Certificate under the Gender Recognition Act 2004 s.9 makes the person's gender their acquired gender for all purposes, including force records.

Pronoun policies: officers should not be compelled to use pronouns they object to, but deliberate and repeated misgendering of a colleague may constitute harassment under the Equality Act (s.26). Reasonable expectation is that colleagues make a good-faith effort to use preferred pronouns.

Officers as victims of hate crime: LGBT+ officers who experience homophobic or transphobic hate crime — whether from the public, colleagues, or outside work — should report it in the same way as any other victim. Force professional standards departments must treat reports of colleague-perpetrated hate crime seriously. Officers may also access third-party reporting through Galop.

Faith and sexuality tensions: forces may face situations where religious belief and sexual orientation conflict. The law does not give one protected characteristic automatic precedence over another. Managers should seek HR and legal advice when managing individual cases.

Female Officer PPE & Uniform

PPE provision for female officers has been a long-standing issue. Body armour and utility belts historically designed for male body shapes do not fit female officers safely or comfortably. This has operational safety implications.

Body armour sizing: female-specific armour carriers are now widely available but take-up depends on force procurement. Officers have the right to properly fitting body armour. Ill-fitting armour may not provide the intended protection and constitutes a health and safety failure.

Pregnancy adjustments: a pregnancy risk assessment must be conducted. Deployment to certain roles (custody detention, public order, armed response) may need modification. Officers cannot be compelled to continue in roles that pose risk to their pregnancy. Lighter duties or alternative deployment should be offered.

Maternity uniform: forces should provide maternity uniform free of charge. Officers should not be required to fund their own maternity clothing. Contact your force HR if maternity uniform is not offered as standard.

Breastfeeding facilities: forces should provide private, clean facilities for expressing milk — not a toilet. Breastfeeding is a legal right in public. Adjustments to shift patterns or access to a refrigerator for milk storage are reasonable adjustments.

Utility belt design: standard utility belts can cause musculoskeletal issues for female officers. Structured waist belts designed for female hips reduce injury risk. This is both an equality and a health and safety issue.

Disability in Policing

Police (Injury Benefit) Regulations 2006 (SI 2006/932): officers who are permanently disabled as a result of an injury on duty are entitled to an injury pension under these Regulations. The degree of disablement is assessed on medical appeal by a board of medical referees. Officers should not be pressured to leave without having injury pension eligibility formally assessed.

Reasonable adjustments: forces must make reasonable adjustments for disabled officers under EA 2010 s.20 (the duty) and s.21 (failure to comply is discrimination). Reasonableness is assessed proportionately — larger forces are expected to make more substantial adjustments than smaller ones. Refusal to make adjustments without objective justification is unlawful.

Medical discharge: if an officer is permanently disabled and cannot undertake any policing duties even with adjustments, the force may initiate a medical discharge process under the Police Regulations. Officers should seek Federation advice before agreeing to any medical discharge.

Disabled Police Officers Association (DPOA): the DPOA provides support, peer contact, and advocacy for disabled officers and staff. Contact them early if you are facing a medical review or fitness for duty process. This is a non-statutory support association.

Mental health as disability: conditions such as PTSD, depression, and anxiety may constitute a disability if long-term and of substantial impact (EA 2010 s.6). This is particularly relevant in policing given high rates of occupational trauma. Officers with a mental health disability are entitled to reasonable adjustments just as those with physical conditions.

Positive Action vs. Positive Discrimination

Positive action (lawful) aims to increase diversity; positive discrimination (unlawful) involves treating someone more favourably solely because of a protected characteristic regardless of merit.

Key Legal Framework