Definition

Internal diversity and inclusion (D&I) policies are documented frameworks setting out a firm's commitments, standards and procedures relating to equality, diversity and inclusion. They typically cover: equal opportunities in recruitment, promotion and pay; anti-discrimination and anti-harassment standards; reasonable adjustment procedures; data collection; and governance arrangements. In an APC context, candidates should know their own firm's D&I policies and be able to explain how they align with the Equality Act 2010 and the RICS Rules of Conduct.

Why this matters for Diversity, Inclusion and Teamworking

  • Level 1 knowledge: you must describe the purpose and main components of an internal D&I policy and explain how it relates to the firm's legal obligations.
  • D&I policies are the organisational expression of Rule 4 of the RICS Rules of Conduct — without effective policies, firms cannot demonstrate the systemic commitment the Rules expect.
  • Assessors frequently ask what D&I policies exist in a candidate's firm and how they are implemented.
  • Poorly designed or unenforced policies expose firms to discrimination claims, grievances and RICS regulatory action.
  • Effective policies create consistent standards reducing the scope for individual discretion to introduce bias.

Key principles

Core components and equal opportunities

An effective D&I policy includes: a commitment statement from senior leadership; the relevant legal framework; definitions of protected characteristics and of discrimination, harassment and victimisation; specific commitments in recruitment, pay, promotion, training and flexible working; a complaint procedure; and consequences of breach. The policy should specify how equal opportunities are ensured, through structured assessments, anonymous shortlisting and diverse interview panels. Firms with 250 or more employees must publish gender pay gap data annually under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

Anti-harassment and reasonable adjustments

A harassment policy sets out what constitutes harassment under s.26 of the Equality Act 2010, the firm's zero-tolerance position and the complaint procedure. The Worker Protection (Amendment of Equality Act 2010) Act 2023 introduced a proactive duty on employers to prevent sexual harassment. The reasonable adjustment duty requires employers to take reasonable steps to remove disadvantage faced by disabled employees or applicants, for example flexible working arrangements, adapted IT equipment or modified duties. The D&I policy should include a clear procedure for requesting adjustments with a named contact, a response timescale and a confidentiality commitment.

Relevant RICS guidance and legislation

  • Equality Act 2010 — nine protected characteristics; prohibition on discrimination, harassment and victimisation; reasonable adjustment duty; equal pay implied term.
  • RICS Rules of Conduct (effective 2 February 2022) — Rule 4: members and regulated firms must treat others with respect and encourage diversity and inclusion.
  • RICS Inclusive Employer Quality Mark — voluntary commitment framework with specific D&I policy criteria.
  • Worker Protection (Amendment of Equality Act 2010) Act 2023 — proactive duty to prevent sexual harassment.
  • Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 — mandatory annual reporting for employers with 250+ employees.

Ethics and Rules of Conduct angle

A firm with a D&I policy that is not implemented, allowing harassment to go uninvestigated or systematically underrepresenting certain groups without action, is in breach of the spirit of Rule 4. Rule 1 (honesty and integrity) requires individuals to engage with these policies honestly, not merely formally.

APC-style Q&As

Q (Level 1)What is the purpose of an internal D&I policy in a surveying firm?

An internal D&I policy sets out the firm's commitments and standards relating to equality, diversity and inclusion, translating legal obligations under the Equality Act 2010 and professional obligations under the RICS Rules of Conduct into practical procedures governing recruitment, progression, anti-harassment standards and reasonable adjustments.

Q (Level 1)What is the reasonable adjustment duty under the Equality Act 2010?

The reasonable adjustment duty requires employers to take reasonable steps to remove disadvantage faced by a disabled employee or job applicant, for example providing adapted IT equipment, flexible working or modified duties. The adjustment must be reasonable in cost and practicality relative to the size and resources of the employer.

Q (Level 2)How does your firm's D&I policy operate in practice?

(example) Our policy covers equal opportunities in recruitment using structured interviews, anti-harassment standards with a named HR contact, a reasonable adjustment procedure with a five-day response commitment and annual diversity data reporting. Senior partners complete unconscious bias training every two years. The policy is reviewed annually by the HR director, approved by the board and issued to all new starters at induction. I am familiar with the reporting procedure and would use it if I witnessed conduct breaching the policy.

Q (Level 2)What is the difference between positive action and positive discrimination under the Equality Act 2010?

Positive action refers to steps an employer may lawfully take to encourage participation from under-represented groups, for example targeted outreach or mentoring programmes. Positive discrimination, that is selecting a less qualified candidate solely because of a protected characteristic, is unlawful. The Act permits a tie-breaker (s.159) where two candidates are equally qualified, but not selection of a materially less capable candidate.

Q (Level 3)A junior team member reports repeated comments about their religion from a colleague. How do you handle this?

(example) I would take the report seriously and listen carefully without pre-judging the colleague or making promises about the outcome. I would follow the firm's formal grievance procedure: informing HR, initiating an investigation by an appropriate manager and ensuring the reporting team member was kept informed and protected from detriment. Repeated unwanted comments related to religion are likely to constitute harassment under s.26 of the Equality Act 2010, creating a legal obligation to investigate and take appropriate action. If the behaviour was confirmed I would support whatever disciplinary outcome HR recommended and review whether team arrangements needed adjustment to prevent recurrence.