What does it take to get into Stonewall’s Workplace Equality Index?

We compared the 2020 and 2022 submission requirements to see what is new. (The most recent submission document is called the Workplace Index Criteria 2021, for the 2022 Index. We compared this with the 2019 document, which is for the 2020 Index.)

More compliance and submission

The aim of the new WEI is to scrutinise organisations for their “LGBT inclusion progress”. There is no reference to the Equality Act 2010 or to rights. 

• The word “equality” has dropped in use from 29 times in 2019 to 26 in 2022, despite the document almost doubling in length.
• The word “inclusion” has increased in use from 8 times in 2019 to 30 times in 2021; “inclusive” has risen from 10 in 2019 to 20 in 2021.
• “Gender” is up from 14 mentions in 2019 to 37 in 2021.
• The word “sex” doesn’t appear at all.

Organisations that submit to the programme must demonstrate compliance with requirements whose questions and guidance run to over 9,000 words. This document is about twice as long as its predecessor, takes a more authoritarian tone, and requires voluminous evidence. 

For an organisation whose main argument for reforming the Gender Recognition Act is to save people the time, money and effort of filling in detailed forms and supplying voluminous paperwork, it seems odd not to consider this in relation to its own scheme. 

Don’t talk about sex!

Stonewall describes its WEI as “the definitive benchmarking tool for employers to measure their progress on lesbian, gay, bi and trans inclusion in the workplace”. Leaders of organisations may think this is about promoting and respecting the rights of same-sex-attracted people and transsexual people. But Stonewall has redefined these words, and awards are only given to organisations that adopt its new ideology of gender.

• The phrase “same-sex”, which occurred only three times in the 2019 document, has disappeared entirely from the 2021 version.
• The words “lesbian” and “gay” get just seven mentions in the WEI document each year.
• “Bisexual” gets no mention at all – replaced by “bi” which went up from 17 counts in 2019 to 24 counts in 2022.
• “Trans” gets the highest number of mentions, increasing from 31 in 2019 to 41 in 2021.

Stonewall does not accept the ordinary – legally defined – understanding of the words lesbian, gay, bi(sexual) and trans(sexual), but instead requires organisations to use Stonewall’s definitions, which relate to the concept of gender identity: “trans” including (but not limited to)

“transgender, transsexual, gender-queer (GQ), gender-fluid, non-binary, gender-variant, crossdresser, genderless, agender, nongender, third gender, bi-gender, trans man, trans woman, trans masculine, trans feminine and neutrois,”

and “bi” as

“an umbrella term used to describe a romantic and/or sexual orientation towards more than one gender […] including, but not limited to, bisexual, pan, queer, and some other non-monosexual and non-monoromantic identities”.

Demonstrate devotion

Many of the criteria for the award are focused not on addressing the particular needs of homosexual, bisexual or transsexual employees, or protecting them from harassment or discrimination, but in demonstrating public devotion to gender ideology.

Points are awarded for observing days, weeks and months in the awareness calendar, such as LGBT History Month, Pride, “IDAHOBIT” (International Day Against Homophobia, Biphobia and Transphobia), Bi Visibility Day, Pan Visibility Day, Trans Day of Visibility, Trans Day of Remembrance and Trans Pride and Non-Binary People’s Day.

There are no points for allowing lesbians and gays to do anything separate from their straight but gender-bending colleagues. For example, employees are encouraged to attend “LGBT-specific conferences and seminars”, “Bi-specific conferences and seminars”, “Non-binary specific conferences and seminars” and “Trans-specific conferences and seminars”.

Don’t talk about women (unless you include transwomen)

Any use of sex-based language or sex-based data within an organisation’s HR systems, or any recognition that women have different needs from men, will see an organisation marked down. Organisations are told: 

• to use gender-neutral language for family-leave policy, including maternity and paternity policies
• that they must “make clear that all trans employees can use the facilities (e.g. toilets, changing rooms) they feel most comfortable using”
• to have “andropause” policies alongside menopause policies (the NHS says that andropause is a misleading and unhelpful term to suggest that men experience something akin to menopause)
• to give “gender fluid people” the ability to have multiple passcards with different forms of gender expression.

Bring your whole self to work: but only if Stonewall approves

Employers are expected to train staff to profess the beliefs espoused by Stonewall, and to recruit, promote and reward those who do. This is called “empowerment”. It is not voluntary.

All “LGBT and non-LGBT employees are to be ‘empowered’ to step up as change makers and allies” through a series of formal programmes and policies. This starts with recruitment, with recruiters encouraged to introduce themselves with their pronouns. 

There should be formal processes “whereby senior employees are mentored on LGBT issues by more junior LGBT employees”. Line managers should “proactively recognise contributions to LGBT inclusion activity during employee performance appraisals”. This must “align with organisational values” to count towards diversity and inclusion objectives. 

LGBT networks cannot be self-organised by the gay, lesbian bisexual and transsexual staff in the organisation who might disagree with Stonewall. They must have officially approved terms of reference or a “formal agreement with an external network”.

And don’t think you can get away with keeping your head down or turning up once a year to tick off the requirements. The guidance says that performance reviews “should be systematic and applied to all performance appraisals, not just those of the network leads”.

Formal programmes “must be more in-depth than a one-off internal communication or event”. Activities must be carried out by senior leaders in all regions or UK nations that you operate in. Speeches at internal LGBT events must be recorded and distributed digitally. Senior leader messages must be written as well as verbal.

The unwritten rule: corrupt your data, ignore data protection, coerce your staff to declare a gender identity

The 9,000-word WEI document, although specific and exacting in many of its requirements, is shy of spelling out what it wants employers to do about diversity monitoring. 

It states several times that “the question wording should be in line with latest good practice. Please speak to your account manager if you are unsure of this.” If you have ever been sold an overpriced gym membership, double glazing or timeshare holiday you will recognise this technique.

What the guidance does make clear is that Stonewall wants client organisations to monitor the sexual orientation, gender and trans status of their staff and customers; and it gives more points for higher completion rates. “Prefer not to say” is not a satisfactory answer. 

What this means, although it is not spelled out, is that Stonewall doesn’t just want employers to collect information from employees who wish to declare themselves as having a gender identity; it wants everyone to be recorded as having a gender identity. It wants employers to stop collecting data on sex, and collect only data on self-declared “gender”. 

Spread the gospel

To be awarded bronze, silver or gold status you must be part of the sales pyramid, promoting Stonewall’s creed through internal and external communications, and scrutinising the adherence of your suppliers.

Organisations are asked to “demonstrate to the largest possible audience that your organisation is committed to LGBT equality”. They are told that their largest social-media channels must broadcast the message.

Potential suppliers must be assessed on whether they have a policy “that explicitly bans discrimination, bullying and harassment based on sexual orientation and gender identity” (even though gender identity is not a protected characteristic). Participants are awarded points for describing “how the procurement team is trained to scrutinise each of these areas”.

Points are also given for supporting “LGBT community groups”, such as LGBT Pride organisations, LGBT equality charities, LGBT youth groups and LGBT networks. Such groups or initiatives could focus on LGBT people of colour, LGBT disabled people or older LGBT people, bi people or trans people. Or they could be “intersectional”. Groups specifically for lesbians or gay men are not mentioned.

Has your organisation done its due diligence on Stonewall?

The gold, silver and bronze awards so proudly displayed today are already beginning to tarnish, with Stonewall’s ill-judged attack on the Equality and Human Rights Commission.

A Civil Service policy paper has told government departments that they should no longer rely on “external assurance and benchmarking organisations”, but should instead take an approach to diversity and inclusion that is focused on:

• eliminating unlawful discrimination
• advancing equality of opportunity 
• fostering good relations between those who share a protected characteristic and those who do not
• being mindful of the privacy of individuals in collecting equality data that is proportionate and necessary.

This is in line with the law, and is equally good advice for private-sector employers, police forces, universities and others.

The Stonewall scheme is a byzantine, authoritarian system of thought control that actively undermines the freedom of expression, self-determination and privacy of anyone whose beliefs differ from Stonewall’s, including lesbian, gay, bisexual and transsexual employees. Organisations that adhere to Stonewall’s requirements are signalling that they are not welcoming workplaces for anyone who does not share these beliefs, and that anyone who expresses non-conforming thoughts should fear the consequences.

People who are discriminated against or harassed at work for not believing in Stonewall’s creed are protected by the Equality Act 2010. The already tarnished medals for ideological compliance may turn out to be a source not only of reputational damage, but also of liability.