Annual diversity and inclusion report 2021 – 2022

Executive summary

Welcome to the summary of our annual diversity and inclusion report 2021-22. The report focuses on how we have implemented our policies and work on developing our strategic equality objectives for 2021 – 2025.

This report sets out the work that we have done over the last financial year in relation to equality, diversity, and inclusion. 

Some of the highlights over the year have been:

  • Our partnership with The Wales Public Body Equality Partnership
  • Equality and diversity project 2021
  • Continuing with our work on ensuring our website is accessible
  • Neurodiversity awareness workshop for our board and executive team members
  • Celebrating and raising awareness of diverse days throughout the year
  • Renewing our Disability Confident assurance
  • Actively promoting awareness and use of gender pronouns

We have an equality, diversity, and inclusion (EDI) forum with staff representatives from across the organisation. The forum is chaired by the Head of People Management. The forum includes the Executive Director of Corporate Strategy and Development who has overall responsibility for EDI within the organisation, one of our board members, executive team EDI Champion, and trade union representatives.

A representative from each of our seven staff networks also sit on the EDI forum, who provide support to staff and are proactive in promoting EDI. Covid-19 continues to be testing for many of our staff and our networks provide essential support during these challenging times.

Over the last year we have largely concentrated on our equality and diversity project 2021 Stages 1 and 2. The has included engaging with staff, stakeholders, and customers to find better and more inclusive ways to reach out and work with our diverse communities across the whole of Wales. This work will help us to better understand how we can work with all our communities. Working collaboratively can help us to shape more inclusive services and enable us to positively reflect awareness of who we are and the diversity of roles in NRW. Through engagement and feedback received our staff, stakeholders and communities have their say and contribute to the work we do. Our aim through increasingly engaging in this way help is to shape fair and accessible information and inclusive services that meet a broad diverse range of priority customer and staff needs for the future. Our approach is: You said. We listened. We did. We fed back.


The Equality Act 2010 places a duty on public bodies to consider the effect our work, policies, and services that we deliver can have on others, including impacts in our own workplace. In summary public bodies must, in the exercise of their functions, have ‘due regard’ to the need to:

  • Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act.
  • Advance equality of opportunity between people who share a protected characteristic and those who do not.
  • Foster good relations between people who share a protected characteristic and those who do not.

The Equality Act 2010 makes it unlawful to discriminate against people with a protected characteristic. The protected characteristics are:

  • Age
  • Disability
  • Gender reassignment
  • Marriage and civil partnership
  • Pregnancy and maternity
  • Race
  • Religion or belief
  • Sex
  • Sexual orientation

We are also subject to the devolved Public Sector Equality Duties Wales as set out in the Equality Act 2010 (Statutory Duties) (Wales) Regulations 2011, noting that listed bodies will undertake:

  • Annual monitoring reports
  • Strategic equality plans
  • Setting objectives
  • Collect and analyse equality information
  • Service user equality information
  • Workforce equality information and workforce pay differences
  • Consultation and engagement
  • Assessing impact
  • Staff training
  • Procurement
  • Accessibility

The Public Sector Equality Duty is part of the Equality Act (2010) and a legal requirement. The broad aim of the general equality duty is to integrate consideration of the advancement of equality, non-discrimination and fostering good relations into everything you do. The purpose of the specific duties is to help in our performance of the general equality duty.

Our duties to promote and use the Welsh language are set in the Welsh Language (Wales) Measure 2011. Our Welsh language standards require that the language is considered in all our decision-making processes and is included as a consideration in our equality impact assessment process, ensuring that both languages are treated equally.

Carrying out equality impact assessment scrutiny on our key changes is about fair and reasonable decision making which considers feedback received to shape inclusive services for people, whatever their background or circumstances. 

Public sector Wales strategic equality objectives 2020 – 2024

Our strategic equality objectives were developed as part of The Wales Public Bodies Equality Partnership and approved by NRW board in September 2020. They were officially launched in March 2021 by Deputy Minister, Jane Hutt MS.

We supported this launch by delivering an aligned promotion with the other partners on our social media accounts. This included articles on our intranet, linking to the engagement events for staff and communities to engage with NRW on the EDI consultation project 2021.

Public sector Wales equality partnership work

In line with the memorandum of understanding for the partnership it was agreed to establish task and finish groups to take forward agreed actions.

The four task and finish groups listed below were agreed and will focus on the following key objective and made up of nominees of staff from the partnership organisations:

  • HR – Diversity and gender pay gap 
  • Procurement
  • Data collection and monitoring 
  • Engagement and service delivery

The remit of each task and finish group is to:

  • Share and exchange information about approaches to delivery, to facilitate learning across the partnership about what constitutes success and best practise.
  • Identify opportunities for sharing and collaborative working which could lead to the development of shared initiatives and programmes of work.
  • Identify and agree actions for change that may need to be taken forward by individual bodies or collectively.
  • Measure and evaluate the impact of any shared initiatives and programmes of work.

The groups started to meet in December 2021, NRW have members of staff on three of the groups namely Procurement, HR and Customer Engagement teams who will report, and where appropriate make recommendations to the main partnership group in due course.

In March 2020, the Board agreed to sign-up to the cross-public sector shared equality objectives and also that we should develop a more specific plan for NRW, tailored to our particular organisational priorities and values. We established a steering group, involving a number of Board members, to help guide our work and have undertaken a number of pieces of work to inform our priorities going forward. 

‘Gyda’n Gilydd - All Together’ NRW's diversity and inclusion strategy 2021-2025

In 2021 we set out to develop our NRW strategic equality objectives supported by a strategy and action plan for delivery.

We want NRW to be an organisation where everyone feels they can participate, where we are open to new ideas, perspectives and innovation, where we are seen as approachable and fair, practicing inclusive ways of working for all. This diversity and inclusion strategy sets out our approach to deliver this ambition.

A focus on diversity and inclusion in all that we do will better enable us to deliver on our strategic purpose (sustainable management of natural resources – SMNR) as an organisation and help us tackle the climate and nature emergencies. A supportive organisational culture that embraces a broad understanding of diversity and inclusion as part of its DNA will be more creative and innovative – qualities that are essential for us to grow given the complexity and urgency of the challenges that we face.

Our EDI consultation project 2021 set out to gather views from customers, staff and stakeholders on our future vision for Diversity and Inclusion. We took the opportunity to review our current position as an organisation, our commitments (including our commitments in the Shared Equality Plan for public sector bodies in Wales), our organisational aims and objectives and those areas where we want to make a real difference over the next 3 years.

Working across the whole of Wales, we consult with the public regularly, but we wish to engage with a wider and more diverse audience and want to find ways to actively engage with under-represented groups, by inviting them to have their say in our work.

As part of that two-stage process, we commissioned an external assessor to undertake an assessment of our activities under the umbrella of equality, diversity and inclusion, seeking views and feedback both internally within NRW as well as from external partners and stakeholders (Stage 1). Following this assessment, we convened a task and finish group (Stage 2) comprised of a representative group of staff from across the organisation, at various grades and across a diverse range of job roles, to help identify our key objectives for the next 3 years (2022-2025). Our strategy is set around 6 objectives, set out below, which have also been influenced by feedback from stakeholders and learning from external initiatives.

  • Bring about a shift in our culture by identifying and implementing initiatives that support everyone to actively listen and model inclusive workplace behaviours
  • Improve the quality of data we capture to enable us to make more informed and better decisions
  • Raise the Diversity and Inclusion bar through ‘living our values’ and by supporting and celebrating our own diversity as well as the diversity of Wales
  • Review the way we use language in our policies and practices in order to create a more inclusive and diverse culture
  • Ensure anyone in Wales, including our existing and new customers, stakeholders, and service users are able to shape our services and easily access our spaces
  • Ensure our policies align with our diversity and inclusion objectives and develop our people in a meaningful way.

We have identified key actions to help us deliver our aims along with indicators that will be used to measure progress. Not all of this will be achieved on our own. We recognise the need to engage with other sectors to hear from their experiences, share in the research, tackle issues much earlier in the lifecycle and much more.

Our strategy was approved by Board on 28 January 2022.


A review of our policies will take place as part of the action plan being developed to help attain the objectives in our strategic equality objectives for 2021 – 2025 to ensure that our polices are inclusive to and support the diverse workforce we aim to retain and attract for the future.

Over the last year six of our policies were reviewed:

  • Leave policy and procedures
  • Menopause policy and procedure
  • Provision of eye-tests and glasses
  • Hand arm vibration syndrome policy and procedure
  • Project and programme management policy
  • Disciplinary policy and procedure

Website accessibility

The accessibility regulations came into force for public sector bodies on 23 September 2018.

We are continuously improving the accessibility of by:

  • re-writing content so that it’s clear for most people to understand
  • publishing content as web pages, as they are more accessible than PDFs
  • converting PDF and word application forms into accessible web forms
  • in exceptional cases of publishing PDFs, we ensure they are tagged in a way that would work better for screen readers
  • testing new websites to make sure they meet the accessibility standards
  • sharing knowledge and guidance so that everyone in the organisation is considering accessibility when creating content for people. 

List of improvements we’ve made to make the website more accessible.

As part of the regulations, we must publish and update the accessibility statement for Natural Resources Wales.

Equality, diversity, and inclusion forum

The purpose of the forum is to bring together staff who are committed to improving and promoting a positive culture around equity, diversity and inclusion with commitment from the board, executive and leadership teams as well as our trade unions.

Note: Equity leads to equality. It is about each of us reaching our full potential; fairness or justice in the way people are treated; with self-determination as a key concept of equity.

Meetings have taken place on a quarterly basis over the last year with the forum concentrating on:

  • Review of equality impact assessment
  • EDI forum events calendar to help co-ordinate future promotion of days and events. This will give EDI forum a plan for the whole year with each event/day will be agreed by the forum, supporting staff networks in collaborative working to promote events.
  • Developing and consulting with a single, holistic work and wellbeing staff passport for NRW.
  • Task and finish group of forum members to discuss NRW response to Welsh Government race equality action plan with a vision for a Wales that is anti-racist by 2030.
  • Neurodiversity awareness session arranged for board members in September 2021, which will also be used more widely within the organisation. Raising awareness session as a manager tool, with managers February 2022.
  • Forum members have scrutinised process and priority recommendations from EDI project stage 1 and 2 with feedback to EDI programme board.

Staff networks

The networks are run by staff for staff and bring together people from all areas of the workplace who identify with others from a similar background or group.

Staff networks fulfil various functions including providing opportunities for social interaction, peer support and personal development. Staff networks can also contribute to the development of our policies and working practices.

As an organisation we value our self-organised groups in creating an environment that respects the diversity of staff and enables them to get the maximum benefit and enjoyment from their involvement in the workplace.

We support the networks by:

  • Encouraging managers to release employees to participate in meeting and targeted work arising
  • Promoting the Networks to new and existing employees
  • Listening constructively to any employee concerns raised through the staff networks
  • Taking part in initiatives developed by the staff network
  • Renewed employers for carers membership January 2022.

We currently have 7 staff networks as follows:

  • Assisted user groups (ICT and telephony)
  • Calon LGBTQ+ network
  • Christian fellowship
  • Cwtch (Carers network)
  • Dementia friends
  • Muslim network
  • Neurodiversity network

In August 2021 our Calon LGBTQ+ network met with Welsh Government PRISM network to discuss their approach to WEI Stonewall submission and sharing good practice on best ways in engaging with staff. Calon hope to continue to collaborate with PRISM moving forward on campaigns.

One member from each network attends the EDI forum meetings, providing an update and a forward look on what the network is involved with. Open conversations for constructive feedback are encouraged at meetings.

Each network gives a presentation at the Induction course for new member of staff to help ensure staff are aware of our networks and the support they can offer at an early stage in their career with us here.

Over the year an events calendar has been developed which helps in having a more coordinated approach to how our staff networks work, making it easier to work together to promote and raise awareness of events.

Information on each of our networks and their purpose can be found in Staff networks information.

NRW support and raising awareness days in 2021-2022

The staff networks were also involved in raising awareness of some of the activities below:

  • March – International transgender day of visibility – organised by calon network
  • May – Dementia action week 17 – 23 may – organised by dementia friends
  • June – Carers week 7 – 11 June – organised by cwtch carers network
  • July – Hajj pilgrimage awareness – organised by Muslim network
  • September – World alzheimer’s day – organised by dementia friends
  • September – Neurodiversity awareness with board and ET members – organised by EDI forum and neurodiversity network
  • November - Carers rights day – organised by cwtch carers network
  • February – Using personal pronouns – organised by calon network

Neurodiversity awareness session

N Network set up 2020

In line with our EDI project 2021 work, the task and finish groups highlighted the need for more training to help in understanding a range of potential barriers that staff with neurodiverse conditions may experience in a workplace setting.

Board and ET members attended the neurodiversity awareness session in September to help them in gaining a better understanding of neurodiverse conditions, the support that’s needed for both staff and managers, and reasonable adjustments that can be put in place which will benefit everyone in their day-to-day work.

Some examples include:

  • Diversity at work: valuing the contributions of neurodivergent people and having different neurodivergent experiences represented is known as neurodiversity.
  • Providing candidates with the questions ahead of the interview. This gives the candidate a chance to fully understand what is being asked and prepare an appropriate response. This helps to make the interview a better experience for both candidate and interviewer.
  • Having quiet workspace and corners in offices for those who find it difficult to concentrate in a busy environment. This can include demonstrating practical mindfulness of extreme sensitivity to bright lights and loud noises.
  • Shorter meetings with regular breaks to help with concentration.
  • Ensuring that written information is followed up with a verbal conversation for a person with dyslexia, ensuring that information is fully understood.
  • Think about the modern office. Most teams hot desk. An autistic person can find this stressful; not knowing where you will sit can present as a real barrier to inclusion. This might sound baffling to some, but changes in environment can have negative impacts. To counter this, consider providing a reserved seat. Without being mindful of neurodivergent colleagues’ needs, you may unknowingly add extra stress to their days.

Further awareness raising sessions have taken place to ensure that managers are aware of the different neurodiverse conditions and the difficulties some may encounter. The session also focusses on the strengths and skills that come with each condition. Gaining a better understanding of each individual colleague’s condition will create a more inclusive culture where Neurodiversity is understood and accepted and retain a more diverse skilled workforce.

Equality impact assessment review

Over the last year the review of the equality impact assessment process has continued asking for feedback from staff completing the assessment with the EDI team providing advice and guidance to staff in discussions and an assurance check on each completed assessment.

The assessment has been built into the Project Manager’s office toolkit gateway 0, for projects and programmes which are taken forward from the service development plan. This helps project managers to consider whether an assessment is required for projects at an early stage in the process and the need to consult and engage with people that our work is likely to have an impact on. This helps in ensuring that views and likely impacts can form part of our decision-making process and find ways to mitigate/re-shape services/policies or reduce the impact our work can have on others.

Awareness of the need to complete an equality impact assessment has been highlighted in the managers’ monthly meeting, for discussion at team meetings.

In the coming year an equality impact assessment stage 1 screening form will be developed to assess whether there is a need to complete a full equality impact assessment prior to start of work or project.

This screening sheet will be a starting point to help in the assessment of impacts process as "we don't know what we don't know" without seeking targeted/reasonable feedback from those who are likely to be impacted before a senior decision is made, using the “You said. We listened. We did. We fed back” approach.

Over the last year 32 assessments were carried out, a list of topics assessed can be found in List of equality impact assessment topics carried out in 2021 to 2022.

Stonewall workplace equality index

NRW did not submit an application to Stonewall workplace equality index (WEI) 2022 due to current work in developing the diversity and inclusion strategy and action plan.

Stonewall change their question criteria every three years with changes this year focusing on evidence of embedding gender-neutral language into our policies. We are further developing our approach to inclusion through language with focus on our Equality Objective 4: ‘Review the way we use language in our policies and practices in order to create a more inclusive and diverse culture’.

Moving forward we will aim to submit every other year; this will give us the opportunity to update policies in line with our EDI project and planned work in readiness for the next planned submission.


From January 2021 until December 2021, we received 2449 applications in total, 820 of these were from internal candidates. As part of our commitment to the EDI strategic objectives and the EDI consultation project 2021, our aim will be to attract applications across our communities to best reflect the diversity of our population in Wales. A breakdown of our recruitment statistics for the period above can be found in this report. The statistics are based on questions asked on the NRW external application form titled ‘Equalities Monitoring Form Recruitment”.

Disability Confident employer

“Disability Confident” is a scheme that is designed to help us recruit and retain disabled people for their skills and talents. This ensures that those with disabilities are guaranteed an interview when applying for vacancies within our organisation where they meet the minimum skill criteria requirements for the role. We successfully achieved re-accreditation to this scheme in May 2021.

Over the last year we have received 32 requests for interviews under this scheme’s guaranteed interview process. Of the 32 requests, 4 requests were from internal staff and 28 from external candidates, with 21 candidates invited to an interview. The other 11 did not meet the minimum criteria requirement for the roles in questions and were declined an interview on this occasion.

  • Further work in developing ourselves as a Disability Confident Employer will form part of our action plan being developed to help attract more disabled people to apply and be successful in securing roles with our organisation – Equality objective 6: Ensure our policies align with our diversity and inclusion objectives and develop our people in a meaningful way.

Staff self-disclosure

We ask and encourage our staff to voluntarily self-disclose personal details such as ethnicity, sexual orientation, religion, faith, belief or no belief and caring responsibilities, confidentially in our central MyNRW HR system. Staff can self-disclose as much or as little information as they feel comfortable in doing, as part of the process. To date 71% of our staff have self-disclosed some or all information voluntarily as part of this process. The percentage of staff who have disclosed has gone up by 3% since last year.

As part of the diversity and inclusion action plan we will look at ways to increase the number of staff who self-disclose. We want to communicate more on the benefits to managers and staff of confidentially self-declaring their profiles. New staff are encouraged to self-disclose and an explanation is given as to why providing this confidential information is important in helping us to understanding the diversity of our workforce as well as and how representative we are to the diversity of the people of Wales. Accurate staff data also enables us to ensure we have the right inclusive policies and support in place to engage more effectively around understanding a diverse range of staff needs.

Overall total 1610 647 2257 71% 29%
Directorate disclosure stats Number completed disclosure Number not completed disclosure Total Percentage completed disclosure Percentage not completed disclosure
Operations 889 405 1294 69% 31%
Evidence, Policy and Permitting 447 144 591 76% 24%
Finance and Corporate Services 119 49 168 71% 29%
Communication, Customer and Commercial 76 28 104 73% 27%
Corporate Strategy and Development 79 21 100 79% 21%

More information can be found in on our staff self-disclosure statistics.

Disclosure includes ‘prefer not to say’ option.

Induction for new staff

All new staff are invited to participate in the induction programme, some of the learning sessions are core and mandatory whilst others are optional. A session under the heading of ‘Caring Organisation’ includes presentations on EDI and Welsh language, along with an introduction to each of our staff networks, this is an optional part of the induction programme.

These presentations help staff to gain a better understanding of what we mean by equity, diversity and inclusion. Focus also highlights the importance of respecting each other’s differences to help in making NRW a diverse, inclusive workplace that welcomes the whole person, and how these differences play an important part in helping NRW to achieve its core purpose as an organisation.

Six presentations on diversity and inclusion have been given over the last year as part of the optional programme. Two induction programmes have taken place over the last year. In total, 1508 members of staff attended the first programme with 1421 attending the second.

All staff are required to complete an online, mandatory diversity and inclusion course. Completion rates are monitored by our learning and development team, with reminders sent to managers asking them to ensure their team complete this mandatory course.

Gender pay gap at 31/3/21

The following shows the reporting outcomes for March 2021 as well as comparisons with previous years.

Measure 2019 2020 2021
Mean 5.3% 2.5% 2.0%
Median 12.1% 3.1% 3.1%


Quartiles Male Female
Lower quartile 53% 47%
Lower middle quartile 50% 50%
Upper middle quartile 54% 46%
Upper quartile 67% 33%
Total workforce 56% 44%


Quartiles Male Female
Lower quartile 54% 46%
Lower middle quartile 53% 47%
Upper middle quartile 52% 48%
Upper quartile 62% 38%
Total workforce 55% 45%


Quartiles Male Female
Lower quartile 53% 47%
Lower middle quartile 54% 46%
Upper middle quartile 51% 49%
Upper quartile 62% 38%
Total workforce 55% 45%

Our gender pay gap information is captured on 31 March each year to comply with The Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017 methodology.


We have improved our mean gender pay gap: the overall mean has reduced by 0.5% from last year’s figure, and by 3.3% overall over the last 2 years.

The analysis results in our gender pay gap show that females on average are paid 98p in the £1.00 compared to males; and based on the median of 3.1% are paid 97p in the £1.00 compared to males’ hourly pay.

We note that the upper quartile shows the broadest variance for proportion of Males 62% and females 38%. This is when compared to the combined workforce figures of Males 55% and females 45% in 2021.

As a comparator in the UK, the mean gender pay gap has fallen from 10.5% in 2011, to 7.0% in 2020, rising to 7.9% in 2021 (ONS: Gender pay gap in the UK 2021), but remains positive in value.

Our median gender pay gap has remained static over the last year, there has been an increased representation of females shown in our lower and upper middle quartiles. On analysis of this data, the gap is not as a result of paying males more than females for the same job – but rather the types of roles that males and females work in and the salaries these roles attract.

There are more males in higher paying roles than females, despite having good representation in leadership roles other high paying roles are attracting more men (STEM i.e. science, technology, engineering, and mathematics, etc.)

Part time working is likely to have an impact on this gap, male employees are less likely to work part time than female employees.

Ethnicity into the environment

A group of environmental organisations in Wales, led by National Resources Wales, have pooled resources and are looking to collaborate with an organisation or individual with expertise and experience of working alongside ethnic minority networks and groups in Wales. The project aims to build understanding of what is already happening and explore where people would welcome support to access, connect with and take action in nature. Our intention is to move beyond just identifying barriers created by the sector to actively dismantling them.

This work is focused on what ethnic minority-led groups would welcome in terms of support and resources to access, connect with and take action for nature. There will be a strong focus on identifying opportunities led by community interest, building on what’s already happening as well as areas that groups or individuals would like to collaborate on. in the future. We want to explore the best way to develop relationships and continue conversations into the future.


Over the last year we received 3 complaints in relation to Equality, Diversity and Inclusion as follows:

Complaint 1

One complaint was received in relation to the temporary closure of a car park and walking path which the complainant said was unsuitable for disabled users. The decision to close the car park and path was following an incident at the site, where a health and safety review concluded that as duty and care for the contractors and members of the public the car park and path would be closed for the duration of the work.

A temporary pedestrian access to some recreation facilities was constructed, with a stock fence along the path edge to ensure user safety. Due to the terrain and the temporary nature of the path, it was unsuitable for disabled access. NRW accepted the complaint that the path was not inclusive, but due to the temporary nature of the work and health and safety of the users that the path was proportionate and acceptable given the circumstances. Security guards were located in the car park to direct and advise people of alternative suitable car parks and trails within a short distance for all.

The temporary arrangements were explained to the complainant.

Complaint 2

One complaint was received noting a number of walking paths in NRW managed woodlands had been blocked by gates which provided no alternative access to wheelchair users. One gate with radar key operation allowing disabled access had been broken, cut and replaced with a normal padlock. Photographic evidence was attached to the complaint. The complaint noted other access restrictions in relation to overgrown vegetation and a barrier with a horse step over.

The complainant was contacted by a member of NRW staff by telephone, given an apology and accepted that work needed to be carried out to ensure the walks were accessible. It was explained that due to the amount of anti-social behaviour particularly off-road motorbikes, barriers are installed to try and restrict access to unlawful users due to accidents and near misses.

To address the matters raised, vegetation was cut back, a padlock was replaced with a radar lock, the horse step over was removed allowing wheelchair access whilst keeping the barrier in place. As an organisation, managing and keeping our legitimate users safe can present challenges along with restricting access to anti-social users.

Complaint 3

A complaint was received in relation to indirect discrimination for reasons relating to a disability breach of section 19 of the Equality Act, which stated that as a publicly funded service NRW were required comply with the public sector equality duties, and engage with Deaf and disabled people, and carry out an equality impact assessment before introducing new procedures, policies or practices. The complaint was in relation to matters noted below:

(a) That installation of an exit barrier and intercom system for out of hours emergency exit at one of our car parks indirectly discriminated against the complainant as someone who considered themselves to be disabled for the purposes of the Equality Act 2010;

Action taken by NRW in response to (a) above is as follows:

It was explained that during the working day, wardens are available at the car park to assist anyone who encounters difficulties at the exit barrier. NRW have worked with the barrier supplier who operates the emergency automated intercom out of hours to ensure that if the emergency button is pressed and no direct contact can be made with the individual, the barrier is released allowing exit from the car park.

(b) That the requirement to provide telephone numbers is mandatory on applications for permissions/permits and as a method of payment for parking permits indirectly discriminates against you as someone who considers themselves to be disabled for the purposes of the Equality Act 2010:

Action taken by NRW to address (b) above is as follows:

It was explained that one of the three methods available for payment for permits requested a telephone number as mandatory. Two other methods are in place, one at the kiosk at the car park and the other at our visitor centre in Coed y Brenin.

NRW are reviewing our online forms to make sure that we ask applicants whether they have any access needs we need to consider in relation to their applications, and what their preferred method of contact is.

The complainant received an apology with the offer to discuss the matter further. We are keen to understand the difficulties faced to try and provide practical solutions and to continually refine our processes to find more inclusive ways of working with disabled customers.

We are currently reviewing the area of fair access to our services/spaces for people with protected characteristics within our strategy/diversity and inclusion action plan.


The findings of this year’s report continue to show that covid-19 has impacted many areas that would be associated with diversity and inclusion across the business, for example our work with external accreditations and events to promote and embed equality further was reduced to support wider programmes to ensure the well-being our staff.

Our major area of work has been to progress our EDI Project 2021 – stages 1 and 2. This staff/stakeholder consultation/engagement process has led to developing six equality objectives within our ‘Gyda’n Gilydd - All Together’ - NRW's diversity & inclusion strategy 2021-25. The strategy was approved by board in January 2022, with an action plan in development.

Our annual Gender Pay Gap (GPG) reporting on 31 March 2021, shows a continuing trend of narrowing our gap, improving the figure this year from 2.5% to 2.0% mean, and remaining static at 3.1% median. However, there has been an increased representation of females shown in our lower and upper middle quartiles.

As a comparator in the UK, the mean Gender Pay Gap has fallen from 10.5% in 2011, to 7.0% in 2020, rising to 7.9% in 2021 (ONS: Gender pay gap in the UK 2021), but remains positive in value.

The GPG analysis results also show that females on average are paid 98p in the £1.00 compared to males; and based on the median of 3.1% are paid 97p in the £1.00 compared to males’ hourly pay.

The findings of our staff profiles analysis show that the broad understanding of diversity of our workforce needs further development within the diversity and inclusion action plan. This includes close links to our engagement and communication plan to help us engage with and attract a workforce that is more reflective workforce of those communities where some of our largest offices are located. In addition, we will focus for example on supporting increased take-up of flexible/part-time working and attracting younger job applicants, through fair and more inclusive processes - as highlighted within our strategy.

The equality impact assessment review has included an end-to-end process map to enable all ‘due regard’ considerations, along with a new stage 1 initial scrutiny template and improved outcomes mapping.

Staff networks information

Calon our LGBTQ+ staff network

The network provides support, guidance, and networking opportunities for NRW’s LGBT+ staff members and allies who wish to support LGBT+ equality and inclusion.

The network migrated from contributors of legacy bodies and was the first official staff network group of NRW in April 2013. To date there are 50 formal members, with 130 following the network on Yammer.

Over the last year the network has been involved with the publication of guidance and the gender pronouns video to the organisation in February 2022, as well as raising awareness of International Transgender Day of Visibility on 31 March 2021.

The network will shortly be nominating a new lead following BR standing down in November 2020, celebrating International Days of Visibility and contributing to Stonewall’s Workplace Equality Index submission.

Cwtch carers network

The carer’s network (Cwtch) group was established in 2019 with the aim of doing more to recognise, support and value our colleagues who care for a loved one. There are around 30-35 on the meeting group membership, and more in the wider yammer network.

Regular meetings have continued to be held throughout 2021-2022 however with increased demands on many members during lockdown times attendance has been relatively low, as has the time capacity of members to be involved in activities. The network has therefore decided to move to more focussed quarterly meetings during 2022-2023 with the aim of increasing availability and attendance. Kate Cameron is the current Chair with Mariella Scott supporting as Secretariat and Annie Payne supporting both roles.

The network has links to other staff networks such as dementia friends and the wellbeing and time to talk groups. One member attends and provides an update at the EDI forum meetings who continue to support the network.

The cwtch Yammer group is active with 80 members and an intranet page available to all staff. This includes guidance for staff explaining the support that is available directly from NRW and through our membership of the employers for carers scheme. During 2022 there are plans to update the intranet pages.

‘Carers Cuppa’ sessions take place monthly, such as the elder care cuppa and ‘A word’ cuppa, and through the yammer group page have recently invited suggestions for any further groups that may be helpful to establish.

In meetings this year the group has discussed:

  • The recently released state of caring report – the UK’s most comprehensive research into the lives and experiences of carers in 2021
  • Using technology to support people living well with dementia
  • Introduction of an NRW carer’s passport and supporting policies and procedures
  • Activities to promote carers rights day and carers week 2021
  • EDI forum support
  • The employers for carers scheme and the resources available to us as continued members
  • How the network can support one another, especially during the pandemic
  • The future of our meetings and what we’d like to get from them

Some of our activities in raising awareness over the last year included:

  • In June 2021 carers week was celebrated, with a strong intranet presence to let people know about the group. With carers blogs where people shared personal experiences of caring and balancing this with their work lives with a focus on caring through the pandemic. We also held several workshops -support for working carers and support for the line managers of working carers, which were expertly facilitated by Jane Healey from Carers Wales.
  • In November on carer’s rights day workshops for line managers were hosted, at the request of some that hadn’t been able to attend previously. Unfortunately, the sessions for line managers weren’t as well supported hoped, due to competing calendar commitments, and a different approach will be taken cascade the recording of one of the presentations to all NRW’s line managers. If, having listened to the recording, line managers have any further questions or would like to chat through some anonymised examples, carers Wales will be happy to assist via some sessions scheduled around relevant calendars. Cwtch are keen to share the advice and support available from carers Wales to all our line manager group and have therefore also offered to organise sessions at other organised meetings (such as executive team or leadership team group) having visible senior support is a key part of NRW’s commitment.

A significant piece of work that some of the members have been involved in this year has been developing NRW’s work and wellbeing staff passport and its accompanying procedure and updating the carers policy and procedure alongside other staff networks.

The cwtch group continue to work with our Diversity and Inclusion Specialist Advisor to link with the ‘Employers for Carers’ scheme and NRW have remained members of the Wales hub, having recently renewed membership for a second year. The aim of employers for carers is to support employers in supporting employees with caring responsibilities and to create carer-friendly workplaces. As mentioned above NRW have access to their publicity, guidance, and training materials, details of which are shared with staff who are carers and their line managers through the intranet, yammer and managers monthly as appropriate.

Neurodiversity network

The neurodiversity network exists to link up neurodivergent staff, along with allies, so that they can support each other and advise NRW on relevant issues.

The network has been in existence since October 2020 with approximately 30 members in total (This figure fluctuates with staff joining and leaving NRW).

Network activities throughout 2021:

  • Advise on management training on neurodiversity and review training providers – we helped locate trainers for the board and had some outdated PCS union training cancelled.
  • Provide links to external information sources on Yammer
  • Provide discussion and sharing platform on Yammer
  • Advise MS Teams setup on suitable backgrounds for neurodivergent staff
  • Presentations on dyslexia and neurodivergence for webinar Wednesdays
  • Representations on NRW EDI meetings
  • Teams’ meetings for members
  • Advising on the use of language describing neurodivergent conditions

It is early days for diversity and inclusion and neurodiversity and although the network has been able to engage very positively with NRW and its D&I plans, the individual situations our members find themselves in remain problematic.

The stigma surrounding being neurodivergent means that many members do not feel in a position to ask for the disability accommodations which they are legally entitled to. 

Forward look for 2022 include:

  • Quick guides for managers and colleagues working with neurodivergent staff or staff who think they may be neurodivergent
  • Staff training on neurodiversity for network members to promote the positive embracing of difference and empower staff to ask for accommodations where needed
  • Work with ODPM to see if adjustments can be better built into HR processes, e.g. by being a reviewed as part of PDP (personal development plan) meetings
  • Briefings on legal rights as staff who are disabled by others’ actions, under the Equality Act e.g., the right to adjustments and to use them, to not face harassment around a protected characteristic.

Important dates:

  • Neurodiversity celebration week 2022: March 14 - March 19

Assisted users ICT group network

The primary role of the assisted user group ICT and telephony is to provide a focal point for matters relating to accessibility. The group is responsible for ensuring NRW is using standard up to date tools and consistent versions, working with ICT governance for management and delivery of any changes.

Activities the group are involved with include:

  • Help test new software
  • Escalate risks and issues to ICT Service Delivery Manager, ICT Service Strategy and Design Manager or relevant member of leadership team
  • Share learning, tips, and tricks between users of assisted technology
  • Group review of further training and guidance needed from outside the organisation
  • Review of progress on current projects relating to assisted user technology
  • Raising awareness of assisted user’s ICT and telephony needs in all parts of the business
  • Ensuring assisted technology requirements are included in new projects from the outset.

The network has been in existence since 2013 and currently have 29 members.

Over the last year the group have tested various applications such as the desk booking system to ensure it’s accessible and where it’s not working with project managers seeking a resolution.

No campaigns or awareness raising was carried out over the last year.

Over the next year the group will continue with testing applications and ensuring that software developed in house or purchased off the shelf is accessible to all.

Dementia friends

Despite continuing to work from home the network has created 95 new dementia friends between Feb 2021 and the end of January 2022, by running virtual sessions linked to both our new starter induction programme and our #TeamNRW staff webinars.

The network has linked their virtual dementia friend information sessions to our NRW induction programme and now all new starters attend a session during their first few months with us. Two sessions are run by the network, the dementia friends awareness session, and a short session about NRW’s journey to becoming a dementia friendly community, the resources that are available to staff and the expectations for staff to be ‘dementia friendly’ in their work. The education and health team and the enabling services PA team also have participated in the awareness session during team meetings.

NRW are now up to 5 accredited NRW dementia champions who can deliver information sessions either face to face or using the new virtual format.

Our dementia friendly work continues to be represented at our ongoing EDI Forum meetings and a ‘caring for elders’ virtual cuppa. The cuppa is supported by a group of a core of 12 people.

Details of our dementia friendly community work are shared on a suite of intranet pages, which the network continues to maintain and update.

NRW continues to participate in a Wales-wide ‘blue light’ dementia group to share learning and best practice. This is co-ordinated by the ambulance service and includes representation from police and fire. Attendance has obviously been impacted this year however going forwards forum members will provide updates about their dementia friendly initiatives and share best practice.

The following virtual training and events were attended, and relevant information disseminated to the business:

  • Dementia friendly communities – people & places training for businesses- Platform Cymru
  • International dementia conference- Alzheimer’s Society
  • Wales- dementia conference- Alzheimer’s Society

The network is participating in NRW’s natur a ni campaign and have met with members of the team to suggest how NRW can involve stakeholders who are either living with dementia or their carers to participate in the campaign.

As a member of the Health, Education and Natural Resources team one of the organisational leads is able to feed into policy development and projects that require knowledge and understanding of people living with dementia and their carers and is supporting the ‘Health’ specialists within this team. Later this month they will be attending a centre for aging and dementia research conference themed around the decade of healthy ageing.

Christian fellowship network

Over the last year the network have continued to adjust to the ebb and flow of covid restrictions have had the constant stability of sharing bible passages and encouragement through the Yammer page. There have often been times when the picture or video shared has really struck a chord with one or more of the group, who are learning more from each other and building stronger relationships, even though many of us have never met face to face. A massive thank you goes to Ian Metcalf for his steadfast approach to sharing amazing pictures, videos, and words every day come what may.

The meetings have also seen an ebb and flow of attendees with different people attending the short monday prayer meetings and the regular the longer lunchtime sessions every other week on a Wednesday or Thursday. The network continues to stand with each other, learning more of God’s grace and favour and going deeper into topics to both inspire and challenge us. Very often this leads into the context of NRW work environment and the need to pray for both the organisation generally and specific groups of staff that may come to mind.

The network has continued to connect regularly in the Monday sessions and the alternate Thursday lunchtime sessions with colleagues in Welsh government – which continues to be a great blessing and surprise advantage of the continuing covid situation.

Over the year the network has started to make more links with the national support organisation for workplace Christian Fellowships – Transform UK. The network is hoping to explore other ways of connecting with them this year and benefitting from the support they can give.

It has also been a blessing to be able to regularly present in the new starter induction programme – the network and thankful that NRW are prioritising staff networks through this programme as it really highlights the support and favour, we have from NRW to continue to meet and be able to prioritise this network and for it to really feel part of the organisation.

The network has been in existence since 2014 and currently there are 30 members in the Christian Fellowship Yammer/email group. Generally, between 5 and 10 attend the networks regular meetings, which changes depending on staff availability.

Muslim network

The network was launched for anyone in the organisation who is a Muslim or would like to find out more about the Islamic faith, meet new people and simply show support as an ally.

The network to exists to raise awareness and help staff to have a better understanding about Islam rather than the negative and sometime Islamophobic exposure they get. This is totally unacceptable and helps no one to live in harmony with each other in a community. 

Diversity and inclusion are an important part of the NRW and therefore, NRW should be committed to making our organisation as diverse as the environment around us. This needs to be given priority by the NRW ET/Board and to go beyond policies.

This is so important as the Islamic community (like other ethnic minority communities) who are under-represented as per the population within the NRW staffing levels. These communities are far away from the reach of the NRW be it in staff numbers or wider engagement. 

List of Equality Impact Assessment topics carried out in 2021 to 2022

The 32 assessments that were carried out were:

  • WISKI project phase 2
  • Social sensing software
  • AssessNet
  • Citizens river habitat survey
  • Community woodland enabling
  • Contract management support service
  • Leave policy and procedures
  • Menopause policy and procedures
  • Provision of eye test and glasses policy and procedures
  • I&D strategy – all together
  • Grants change programme
  • HAV’s policy and procedure
  • Llyn Tegid project review
  • Microsoft Teams project
  • Microsoft Teams phase 3
  • Natur a ni
  • NRW corporate plan 2022 – 2027
  • EDI project overview stages 1 and 2
  • Telemetry system replacement
  • Office booking system
  • PPM policy
  • Retrospective Newborough car park
  • Stephenson Street flood alleviation scheme
  • Water abstraction reform
  • Disciplinary policy
  • Further education policy
  • Permissions development and innovation project
  • Potential outcomes of contractual rotas project
  • Well-being staff passport
  • Carers passport
  • Reasonable adjustments policy

Recruitment statistics for January 2021 to December 2021

Note: data below 10 is shown as a 'Below 10' for data protection purposes.

What is your age group?

Age group Total
16-24 354
25-34 619
35-44 373
45-54 181
55-64 81
65 plus Below 10
Prefer not to say 15
Blank Below 10

What is your gender?

Gender Total
Male 940
Female 675
Non binary 16
Prefer not to say Below 10

Does your gender identity match the sex you were assigned at birth?

Gender identity Total
Yes 1605
Prefer not to say 12
No Below 10
Blank Below 10

Are you currently married or in a civil partnership?

Married or civil partnership Total
No 1146
Yes 455
Prefer not to say 23
Blank Below 10

What is your sexual orientation?

Sexual orientation Total
Heterosexual/Straight 1446
Prefer not to say 74
Bisexual 51
Gay man 30
Gay woman / Lesbian 17
Prefer to use own term Below 10
Blank Below 10

What caring responsibilities do you have?

Caring responsibility Total
None 1259
Primary carer of children (under 18) 252
Secondary carer 73
Prefer not to say 36
No record Below 10
Primary carer (over 65) Below 10
Assisting in caring Below 10

Do you consider yourself to have a disability?

Disability  Total
No 1578
Yes 42
Prefer not to say Below 10
Blank Below 10

Guaranteed interview requests

Requested Total
No 221
Yes 32
No record 1376

Guaranteed interview offered

Interview offered Total
Yes 21
No (No offer due to not meeting minimum required criteria) 11

What is your religion or belief?

Religion or belief Total
Have no faith or belief 945
Have faith or belief 580
Prefer not to say 103
No record Below 10

What is your ethnicity?

Ethnicity Total
White (English, Welsh, Scottish, Northern Irish, British, Irish, Gypsy or Traveller, any other White background) 1521
Prefer not to say 32
Asian/Asian British
(Indian, Pakistani, Bangladeshi, Chinese, any other Asian background)
Other ethnic group
(Arab or any other ethnic group)
Mixed/Multiple ethnic groups
(White and Black Caribbean, White and Black African, White and Asian, any other mixed/multiple ethnic background)
Black/ African/Caribbean/Black British
(African, Caribbean, Any other Black/African/Caribbean background)
No record Below 10

Self-disclosure stats 2021 – 2022

See self disclosure statistics 2021-2022

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