The Independent Living Fund Scotland (ILF Scotland) believes that no-one should be denied opportunities because of their race or ethnicity, a disability, their gender, or sexual orientation, their marital or civil partnership status, their age or religion, or due to any of the protected characteristics detailed in the Equality Act.
ILF Scotland will treat recipients, applicants and ILF Scotland staff equally and fairly. For staff, this commitment also extends to maternity status, working pattern, employment status, caring responsibility, and trade union membership.
ILF Scotland must comply with the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 and the specific duties designed to help Scottish public authorities meet the general duty. Regulation 4 of the specific equality duties requires that we base our Equality Outcomes on evidence, and involvement of equality groups.
The Public Sector Equality Duty regulates performance against equalities duties. From April 2020, ILF Scotland is required to report on the areas outlined below, every two years, apart from the Statement on Equal Pay, which is every four years. We also have a duty to publish diversity information about our board members. This report meets our general and specific duties under the Equality Act 2010 and outlines:
The public sector equality duty came into force on 5 April 2011. The purpose of the duty is to ensure that public authorities consider how they positively contribute to a more equal society. It requires authorities to consider equality in all their functions, including decision-making, design, and delivery of services.
From 1 October 2012, the scope of the Act was extended to ban age discrimination, though this does not presently cover people under the age of 18.
The aim of the Equality Duty Action Plan is to demonstrate ILF Scotland’s commitment to the Scottish Government’s equalities agenda, mitigate the risk that equalities activities are not prioritised and align the activities with budgets and resources to cover short and medium-term objectives.
Under the Equality Act 2010, public authorities are required to have due regard to the need to:
This duty is often referred to as “the three needs.” To comply with the duty, a public authority must have due regard to all three of these needs.
The Act explains that to meet the second need (advancing equality of opportunity), a public authority must consider the need to:
The Act also sets out that:
Who should be aware of the General Duty in ILF Scotland?
Set strategic direction, review performance, and ensure good governance of the organisation. The Depute Director, Scottish Government, Health and Social Care, appraises the Chair of the Board against a Diversity Objective.
Oversee the design, delivery, quality, and effectiveness of the organisation’s functions.
Specific role in raising awareness and building capacity about the general duty. The Equality Lead in ILF Scotland is the Chief Executive Officer.
Help ensure relevant equality information is available and accessible.
Need to be aware of how they can help to meet the needs of people with special characteristics.
Need to be aware of how to build equality considerations into the organisation’s supply chain. In ILF Scotland, anyone tendering a contract should be aware of the Equalities Obligation and what we expect of organisations that we contract with.
Need to consider and be aware of how they apply Equality Duty on a day-to-day basis with reference to organisational employment policy and practice.
The primary function of ILF Scotland is to operate a discretionary fund providing financial awards to over 4,000 disabled people in Scotland and Northern Ireland to help them live independently. ILF Scotland adheres to a suite of key policy documents to support our recipients, applicants, and staff. The policy suite is updated on an ongoing basis to support the Scottish Government’s strategic priorities.
The key references are:
ILF Scotland Strategy 2025 to 2028
ILF Scotland recognises the need to consider whether and how the outcome and delivery of any proposed new or amended policy might impact on people, specifically, what relevance the policy might have to people with protected characteristics.
The policy development lead will carry out a screening exercise to help determine if any proposed or amended policy / practice will directly or indirectly affect people. They should then complete either an Equality Impact Assessment (EQIA) or the No EQIA required declaration.
The policy lead must carry out the EQIA early, and as an embedded part of the policy development process, so that the assessment can shape, inform, and influence the policy proposals, and they should continue to revisit this assessment throughout the lifecycle of the policy.
The vision set out in the Strategic Plan identifies the integral part played by ILF Scotland in supporting independent living for disabled people across Scotland and Northern Ireland, and how ILF Scotland can support individuals through its funding role.
ILF Scotland will improve its evidence base by gathering information from recipients, applicants, and staff through the various use of equality monitoring forms, and where applicable, will use surveys, to strengthen its understanding of the needs and requirements of the disabled people the organisation supports.
This improved data will be reflected in enhanced information displayed in the Annual Corporate Report and online. Stronger management information will enable ILF Scotland to consider how it can better meet the general equality duty, its specific duty under the Act, and improve its service delivery.
Action:
Engage opportunities to encourage diversity of our Board membership and create dialogue with under-represented groups (specifically disabled people).
General Equality Duty:
Advance Equality of Opportunity
Owner:
Chair of the Board
Review:
Ongoing through specific engagement opportunities
Action:
Ensure that all our staff follow SSSC’s and NISCCs Codes of Practice. The Code is part of our Induction Pack for all staff. Refresher and updates are delivered as required.
General Equality Duty:
Eliminate Discrimination
Advance Equality of Opportunity
Foster Good Relations
Owner:
Director of Independent Living
Review:
Completed and ongoing.
Codes of Practice | Scottish Social Services Council
Action:
Continue to amend our website to create clear visual communication, making appropriate use of audio / video and social media platforms, to increase accessibility and reduce barriers for disabled people.
Follow good practice guidance on design for our website and all publications and provide documents in alternative languages and formats on request.
General Equality Duty:
Eliminate Discrimination
Foster Good Relations
Owner:
Director of Policy
Review:
New improved website with greater emphasis on accessibility, live June 2022. Achieved new UK Government Standards on Accessibility.
Diversified and extended use of social media platforms.
Improvements made to Fund literature in the Transition Fund application process.
Accessibility internal working group established to review key material.
Focus on making all key public documents accessible.
Action:
EQIA exercise to be carried out and EQIA published for all new and revised external policies, the framework of this is determined by Scottish Government Ministers.
EQIAs to be completed for other key business decisions
General Equality Duty:
To comply with Equality Legislation and good practice
Eliminate Discrimination
Foster Good Relations
Owner:
Director of Policy
All Heads of Departments
Review:
Completed and ongoing.
Completed - EQIA Training for Management Team – May 2025.
Ongoing refresher training will take place regularly.
Action:
Improvements to application forms and guidance, all designed to be clear and accessible. Including access to Gaelic Language forms.
General Equality Duty:
Advance Equality of Opportunity
Foster Good Relations
Owner:
Director of Policy
Review:
In progress and ongoing – Gaelic Language forms not yet developed.
Action:
All roadshows and events undertaken in accessible venues, with as wide a geographic spread as possible, bi-lingual advertising in Gaelic-speaking communities.
General Equality Duty:
Advance Equality of Opportunity
Foster Good Relations
Owner:
Director of Policy
Review:
Ensured all engagement events for the Independent Living Fund re-opening were held in accessible venues and that all related communication was produced in Plain Language and Easy Read. No events were held in Gaelic Language speaking localities.
Action:
Equality check carried out on Board papers and all publications / key documents to ensure written communication is gender neutral.
General Equality Duty:
Eliminate Discrimination
Owner:
All Heads of Department
Review:
Ongoing
Action:
Equality clauses added to all contracts as part of tendering / procurement process and submissions measured against equality criteria.
General Equality Duty:
Advance Equality of Opportunity
Eliminate Discrimination
Owner:
Head of Finance
Review:
Ongoing
Action:
Denholm House is an accessible building with an induction loop. ILF Scotland promotes such provision through its service level agreement with the Scottish Government.
General Equality Duty:
Foster Good Relations
Owner:
Chief Operating Officer
Action:
Through our Corporate Parenting Plan, we will further develop our communications strategy to target care experienced young people and those that support them to ensure they are aware of ILF Scotland Transition and Re-opened Funds.
We will ensure ILF Scotland staff and Board Members are aware of the principles of Corporate Parenting through training courses and induction programmes.
General Equality Duty:
Advance Equality of Opportunity
Owner:
Director of Policy
Review:
Communications Strategy updated.
Completed - Training delivery September / October 2024
Action:
Facilitate meetings of the Co-Production Working Group every two months in 2024 to 2025, with the first meeting to be scheduled for June 2024.
Report on learning from the first two months of receiving applications to the re-opened fund and work together with the group and others as required to further develop policies around the key issues raised by disabled people and others at the re-opening engagement events.
Arrange further co-production opportunities with our recipients and others as part of our strategic planning consultations in the latter part of 2024 to 2025.
General Equality Duty:
Advance Equality of Opportunity
Foster Good Relations
Owner:
CEO
Director of Policy
SLT
Review:
Ongoing
Action:
Offer employment opportunities for volunteer / student placements for young people with a disability that places them at a significant disadvantage in the job market.
Offer social work student placements to promote the Social Model of Disability within statutory social work.
General Equality Duty:
Advance equality of opportunity
Owner:
CEO
Director of Independent Living
Review:
Student placements opportunities offered annually – September 2025
Action:
Continue induction training for Board Directors and staff on Diversity and Equality.
General Equality Duty:
Eliminate discrimination
Owner:
Director of Business Services
Review:
Ongoing - DET Training for all staff and Board Directors during induction.
Action:
Gaelic Language Plan, with responsibility held at Senior Management level, helping to raise awareness and culture of relevance to ILF Scotland’s staff and recipients.
General Equality Duty:
Advance equality of opportunity
Foster good relations
Owner:
Director of Policy
Review:
Awareness training delivered across the organisation – Feb 2022. On hold since then due to other completing priorities and no requirement currently for legislative compliance. Will pick up in next Strategic Plan.
Action:
Information on Equality and Diversity is included in the Staff Handbook / HR Policies and forms part of the Induction for new staff.
General Equality Duty:
Advance equality of opportunity
Eliminate discrimination
Foster good relations
Owner:
Director of Business Services
Review:
Complete and ongoing for new staff. Refresher sessions for current staff.
New Equality and Diversity Policy published June 2025.
Action:
ILF Scotland continues to promote best practice in making sure the office space is suitable for people with differing needs, for instance with an induction loop and disabled access to the building.
General Equality Duty:
Foster good relations
Eliminate discrimination
Owner:
Finance and Business Services
Review:
MOTO and Shared Service Agreement with the Scottish Government.
Action:
Adhere to ILF Scotland HR policies on equality and diversity in the workplace, including work-life balance, development, promotion, work opportunities and recruitment.
General Equality Duty:
Advance equality of opportunity
Owner:
Director of Business Services
Review:
Completed for all staff and on-going refreshers.
Action:
Regular Conversations take place between staff and line managers and include specific reference to wellbeing to allow any concerns to be acted on.
General Equality Duty:
Foster good relations
Eliminate discrimination
Owner:
Director of Business Services
Review:
Ongoing regularly through 1-2-1s and training.
Action:
Continue to increase awareness of mental health issues as an equality issue.
General Equality Duty:
Advance equality of opportunity
Eliminate discrimination
Foster good relations
Owner:
Director of Business Services
Review:
7 x Mental Health First Aiders.
Mental Health and Personal Resilience training offered regularly to all staff and Board Directors.
Action:
Continue to increase equality for disabled people living in poverty
General Equality Duty:
Socio-economic duty
Owner:
Director of Independent Living
Review:
Provide regular welfare rights and income maximisation training to all operational staff.
Provide an in-house welfare rights service for staff to respond to ILF recipients.
Action:
ILF Scotland adheres to the SG (Scottish Government) Fairness at Work policy, which covers equality and diversity.
General Equality Duty:
Foster good relations
Eliminate discrimination
Owner:
Director of Business Services
Review:
Work with recognised union - PCS to ensure ILF Scotland works to the Fairness at Work principles.
Action:
Raise awareness of neurodiversity and provide staff training to cover this area specifically as part of our equality and diversity training. Provide more detailed training to front line staff working in both Funds so that they can provide better informed customer service to those applications and recipients who are neurodivergent.
General Equality Duty:
Advance equality of opportunity
Owner:
Director of Business Services
Review:
Raise awareness workshops between 2024 to 2026 (underway)
ILF Scotland has designed its induction procedures to ensure diversity issues are included and staff are aware of a range of advice, guidance and support provided by ILF Scotland HR team.
ILF Scotland will treat all staff equally irrespective of their sex, marital / civil partnership status, maternity status, age, race, ethnic origin, sexual orientation, disability, religion, or belief, working pattern, employment status, gender identity, caring responsibility, or trade union membership.
ILF Scotland is committed to increasing the diversity of staff within the organisation. We will develop all our staff, ignoring all irrelevant differences, in their management and development. Furthermore, we will positively value the different perspectives and skills of all staff and make full use of these in our work.
Active consideration of equality will help ILF Scotland to identify ways in which to improve evidence gathering and engagement, to help improve the quality of services it provides, making them more responsive to customer and staff needs, leading to better outcomes.
Senior Managers and Board Directors have a vital role to play in giving a clear and consistent message about the importance of promoting equality and diversity. Through visible leadership, the Senior Leadership Team will ensure that it reflects equality in performance reporting and that staff are clear ILF Scotland adopts a zero-tolerance approach to discriminatory behaviour and builds the capacity of all staff to consider and promote the equality duties.
Protected Characteristics
Age
Disability
Gender reassignment
Marriage and civil partnership
Pregnancy and maternity
Race
Religion and belief
Sex
Sexual orientation
Socio-economic background
The socio-economic duty is contained in Section 1 of the Equality Act 2010 although it has never been enacted. The duty would require public authorities to actively consider the way in which their decisions increase or decrease the inequalities that result from socio-economic disadvantage. ILF Scotland is committed to supporting disabled people living in poverty.
Action:
Staff satisfaction survey – use to provide data on bullying and harassment, wellbeing, and opportunities. Compare data in-year. Consider adding question to survey to seek staff ideas on improving diversity.
General Equality Duty:
Advance equality of opportunity
Eliminate discrimination
Foster good relations
Owner:
Director of Business Services
Update:
Working group formed annually to consider survey and improve offering
Review:
2024 to 2025 Staff Survey completed.
Action:
The TF online application process reduces access barriers to recipients as they do not need to phone or write to us to access information and do not need to complete a written application form.
General Equality Duty:
Foster good relations
Owner:
Director of Policy
Update:
Online application process improvements implemented 2020 to 2021.
Review:
Keep opportunities for further improvements under review. Ongoing.
Action:
Equality and Diversity given high profile in induction training for Board Directors
General Equality Duty:
Advance equality of opportunity
Foster good relations
Owner:
Director of Business Services
Update:
New Board Directors 2023 onwards
Review:
New Board Directors attend Disability Equality Training. Board Directors attend Neurodiversity workshop sessions 2024 to 2026.
Action:
Increase awareness of cultural importance of Gaelic and promote learning by providing training and BnG presentation to Board.
General Equality Duty:
Foster good relations
Owner:
Director of Policy / Director of Business Services
Update:
Progress started on a voluntary basis at present well in advance of requirement to produce Plan in full.
Review:
On hold
Action:
Ensure all venues for roadshows are accessible and bi-lingual advertising in Gaelic-speaking areas.
General Equality Duty:
Eliminate discrimination
Foster good relations
Owner:
Director of Policy
Update:
No public events held in Gaelic-speaking areas.
Action:
Actions to promote increased awareness of Mental Health in the Workplace
General Equality Duty:
Advance equality of opportunity
Eliminate discrimination
Foster good relations
Owner:
Director of Business Services
Update:
Training:
Supporting each other in a Crisis - April 2020
Personal Resilience - March 2021
Returning to Workplace - May 2022
7 x Mental Health First Aiders trained and in post.
Review:
Continue Mental Health and Resilience workshops and raising awareness annually (completed October 2025).
