LGPS 2014 PROPOSALS – EQUALITY IMPACT ASSESSMENT PUBLISHED
1. EQUALITY IMPACT ASSESSMENT
The equality impact assessment (EIA) on the LGPS 2014 proposals has now been published and has been posted on the UNISON Pensions web site at http://www.unison.org.uk/acrobat/LGPS2014EIAReport.pdf.
The EIA was carried out by Diverse Cymru – an independent Welsh equality consultancy – at the request of the joint negotiating team, consisting of the LGA, UNISON , GMB and Unite. It covers Workstream 1 of the negotiations over LGPS 2014 – the proposals which over 90% of UNISON members taking part in the recent ballot have accepted. It does not touch on the current or previous versions of the LGPS.
The EIA has taken longer than expected, due to the extent of the detail covered by the proposals and required to be covered in the EIA by the negotiating team.
Why an EIA?
The general Public Sector Equality Duty requires public bodies to have ‘due regard’ to the need to:
• Eliminate unlawful discrimination, harassment and victimisation
• Advance Equality of Opportunity between persons who share a relevant protected characteristic and persons who do not share it
• Foster good relations between persons who share a relevant protected characteristic and persons who do not share it
The ‘relevant protected characteristics’ (PC’s) are age, disability, sex, gender reassignment, pregnancy and maternity, race, religion or belief and sexual orientation. Marriage and civil partnership are only covered by the first requirement above – the elimination of unlawful discrimination, harassment and victimisation.
There is a requirement to collect data across the PC’s to meet the above requirements.
General findings of the EIA
• There was a lack of available equality data especially for sexual orientation, gender reassignment, pregnancy or maternity and religion or belief
• The requirement to collect PC data is ‘relatively new’ and would cover over 5000 LGPS employers
• Diverse Cymru ‘strongly recommend’ that the lack of data is addressed as a priority issue by ‘collating or putting in place mechanisms to collect data across all PC groups’
• Since collection of quantitative data is likely to take some time, qualitative data ‘to help evidence/inform a more definitive viewpoint’ should be collected in the interim
• Data on ‘opted outs’ should also be gathered
• Future information on the LGPS should follow Plain English, Easy Read and Cymraeg Clir guidelines
• It should also be available in community languages and other accessible formats on request
• The availability of these formats should be advertised in a large print, clear statement
EIA RESPONSE TO KEY ASPECTS OF LGPS 2014
CARE with 1/49 accrual and CPI revaluation
• This proposal would disproportionately impact on high earners and those likely to experience career progression
• It would be an improvement for those on low pay and with low progression prospects
• It would be helpful to ensure that LGPS members are aware of the different basis of the LGPS
Pensionable pay to include additional hours and non-contractual overtime
• Positive for part-time workers who work additional hours – most of whom are women
• Likely to be beneficial for disabled people, who are more likely to work part-time than non-disabled people
New contribution bands and rates
• Contributions based on actual earnings – not full time equivalent – will benefit the 47% of women and 7% of male employees eligible to join the LGPS who work part-time
• Since 95% of members will have no contribution increase, all protected groups will benefit, unless amongst the 5% of high earners facing contribution increases
• Annual benefits statements will ensure that high earning members are aware of benefits accrued and the ability to purchase additional pension
Introduction of the 50/50 option
• Could be positive for people facing short-term financial difficulty
• But could lead to some women and disabled people facing poverty in retirement
• Should have the positive effect of increasing the opportunity for lower paid women employees to save for retirement
Normal Pension Age (NPA) to equal State Pension Age (SPA)
• Raising the SPA to 66, 67 and beyond will have a disproportionate impact on men as their life expectancy is 3.8 years less than women’s
• Retiring at 67 only gives men 11.1 years pension on average, compared to 15.1 years for women
• Life expectancy is likely to be shorter for disabled people, who would also suffer a greater loss of pension than women in general
• This is also likely to be true of some black and ethnic minority (BME) groups
Reducing the vesting period to two years
• This would be less attractive to short-term employees, especially those on the lower pay points, who might be more likely to be women or younger people
• The protections for those nearing retirement will have a positive impact for men and probably white people who predominate in the higher earners group
ACTION PLAN TO ADDRESS ISSUES IDENTIFIED BY THE EIA
The actions for the LGPS negotiating team and future Governance Board identified in the EIA process are:
• Put ‘robust mechanisms’ in place for collection of PC data not available
• Seek qualitative feedback via contact with scheme members, PC groups or existing trade union PC groups
• Seek qualitative feedback via member surveys or focus groups of PC members
• Use both quantitative and qualitative data to act on any adverse impact
• Introduce processes by which equality issues can be raised in an easily accessible and safe manner
• Produce regular information and briefings
• Ensure that information on the LGPS is available in a range of formats and languages
2. WORKSTREAM 2 CONTINUES
The negotiating team is continuing to meet to finalise proposals for governance of the LGPS 2014 and for the future cost management mechanism. This will seek to ensure that the costs of the scheme do not increase, requiring further changes to benefits or contributions.
UNISON has long campaigned for Member Nominated Reps to have a greater say over how the LGPS is run, how members’ contributions are invested and other key decisions affecting your pension. We will be convening meetings of UNISON LGPS contacts and existing LGPS reps to continue to push for adequate representation on funds and for training to help reps fulfil their duties.
3. THERE IS STILL WORK TO DO….
It is vital that all stewards and pension contacts/champions help to make members aware of the contents of LGPS 2014 and what it means for them. We need to ensure that non-members realise that it was UNISON which led the fight to stop contribution increases and to ensure that any changes to the LGPS did not impact negatively on membership. You can still use the outcome of the negotiations and the ballot to recruit non-members to UNISON. Let them know of our plans to have an ongoing involvement and influence over the future of the LGPS
4. WANT TO BE AN LGPS PENSION CONTACT?
If you would like to be an LGPS contact or champion and keep members in your workplace informed about UNISON’s work on the LGPS and keep your members up-to-date on their pension scheme, please contact Indira Patel on firstname.lastname@example.org