The equality plan is to be drawn up in cooperation with employee representatives.
Drafting an equality plan
The gender equality plan is to be drafted in cooperation with the shop steward, elected representative, occupational safety delegate and other representatives appointed by the employees, and these people must have sufficient opportunity to participate in and influence the planning process. This means that the employee representatives must be guaranteed real opportunities to participate in plan preparations and have an influence on the content of the plan in the different stages of its development. The employer must give the employee representatives sufficient information for understanding the task in hand.
When the equality plan is incorporated into the personnel and training plan or the occupational safety and health policy, legislation on cooperation must be applied. Other procedures for local agreement can also be applied when drawing up equality plans if these are in use and they have been agreed upon separately.
A separate plan or incorporated into other plans?
According to the Equality Act, the gender equality plan may be incorporated into a personnel and training plan or an occupational safety and health policy.
Both the reports commissioned by the Ombudsman for Equality and the Ombudsman's experiences on equality work carried out in workplaces are in favour of a separate equality plan. Separate equality plans contain more concrete actions to promote equality than plans which are simply incorporated into the personnel and training plan or the occupational safety and health policy. Drawing up the equality plan and the personnel policy non-discrimination plan together may be sensible, as they both relate to preventing discrimination and developing an equal work community.
However, drawing up a separate equality plan and incorporating the plan into the personnel and training plan or the occupational safety and health policy do not necessarily rule each other out. As the equality work should be part of the normal personnel policy, it is only natural that when the equality plan has been drawn up, the measures which have been planned to be initiated or carried out are included in other documents and plans regarding the personnel.
According to the impression of the Ombudsman for Equality the equality plan should be – no matter what its physical form – a clear and defined whole which can be found and presented without difficulty and which contains the sections which are defined for the equality plan (assessment, measures, evaluation).
On which organisational level should the plan be drawn up?
Employer organisations vary a great deal and the organisational structure can also affect how the equality plan is carried out. When considering which organisational level the plan should be drawn up on, the organisation of the decision-making regarding HR administration is of great importance.
There are small companies where all employer obligations are taken care of in a specific unit. On the other hand there are employers with many sub organisations and where the power of decision has been divided between different levels. When the organisation is large and has many levels it is not enough to have one equality plan for the entire organisation; instead, purposeful and planned equality work requires that the sub organisations also carry out equality planning and monitor its implementation.