Equality Impact Assessment (Interim) - Net Zero Action Plan 2024

Equality Impact Assessment: initial screening

Please complete the form using the blank rows, as well as the greyed out boxes containing guidance that you should overwrite.

What is being assessed by whom?

• Name of the policy: Net Zero Action Plan
  (The term policy is shorthand for policies, provisions, criteria, functions, practices and activities including the delivery of services).
• Name of person leading the assessment: Carole Wells, pending recruitment of Net Zero Leader
  (Person leading on the policy development).
• Names of other team members: NatureScot’s Net Zero Group
• Is this a new or existing policy? Existing being reviewed
• If existing, then please check to see whether a previous EqIA is available to provide a basis for this assessment. 

Initial screening

• Does the policy impact on people? (e.g. on service users, businesses, employees, wider community): Yes
• Will it have a significant effect on how other organisations operate? Yes
• Does it relate to an area where NatureScot has set equality outcomes (Quality Report 2019)? Yes
  (Across the range of our activities, more people from minority ethnic (ME) communities, people with disabilities and disadvantaged families, individuals and communities enjoy and benefit from nature. Through changes to recruitment and attraction procedures more people from ME communities and people with disabilities apply for opportunities with Scottish Natural Heritage (SNH). We have an age-inclusive culture that supports and values everyone.
  We have reduced the gender pay gap to 9%).
• Does it relate to an area where there are known inequalities? Yes

If you answered Yes to any of the above, please proceed to Stage 1 of the EqIA form.

If you answered No to all of these, you do not need to carry out an EqIA so proceed to sign and complete the statement below.

An EqIA is not needed Date:

Signed

Lead officer: Carole Wells, 15 April 2024
Responsible officer (Person with overall responsibility for the policy): Stuart MacQuarrie, 15 April 2024

Please now publish the initial screening section of the form in the eRDMS (Equality Impact Assessment: initial screening) and email confirmation to [email protected] Please also retain a copy with your policy documents.

Equality Impact Assessment: assessing impact 

Stage 1. The purpose of the policy, service, activity etc.

What is the purpose of the policy?

NatureScot has presented its first Net Zero Plan to lead the organisation through the necessary transformation required to play its full and active part in a transition to a low carbon economy and nature rich future. 

The Plan presents NatureScot’s view of how we can achieve our ambition to be Net Zero by 2035. We already have a 2040 zero direct emissions target but we are going further with our 2035 Net Zero stretch target. 

NatureScot Net Zero Plan - July 2021 (internal link)

Who does the policy affect? (employees, customers, equality groups, stakeholders)

Please describe who the policy might affect and how, and who might benefit from the policy and in what ways.

The Net Zero Action plan shows each action and sets out the benefits. The actions to reduce carbon emissions affects all of us: the public, our staff, our co-locatees in shared buildings, our external suppliers.

What results/outcomes are intended?

Net Zero means achieving a balance between the greenhouse gases put into the atmosphere and those taken out. 

We are seeking to achieve our target by reducing our operational emissions and working to decarbonise the estates through developing and investing in further renewable energy 4 system at our offices and on our land. To reach Net Zero, all emissions will need to be cut. Whilst this is our first Net Zero Plan, the organisation has been driving emissions reductions for a number of years through our Greening initiative. 

Details about the changes that people will see are outlined in the Net Zero Plan. 

The Net Zero Plan will be refreshed in the new Financial year, so in 2024-25.

Stage 2. Relevance to the needs of the general equality duty 

Please consider which aspects of the policy are relevant to the three needs of the general equality duty.

Eliminate unlawful discrimination

This refers to discrimination because of a person's protected characteristic (direct); or discrimination that occurs when a provision, criteria or practice is applied that creates disproportionate disadvantage for a person with a protected characteristic as compared to those who do not share that characteristic (indirect).

Advance equality of opportunity

For example, this involves:

• Removing or minimising disadvantage suffered by people due to their protected
  characteristics.
• Taking steps to meet the needs of people with certain protected characteristics where
  these are different from the needs of other people.
• Encouraging people with certain protected characteristics to participate in public life or
  in other activities where their participation is disproportionately low. 

Foster good relations between groups of people

This means fostering good relations means tackling prejudice and promoting understanding between people from different groups.

Stage 3. To which of the equality groups is this policy relevant?

• All - Yes
• Sexual orientation
• Age
• Gender reassignment
• Disability
• Pregnancy and maternity
• Gender
• Religion and belief
• Race
• Marriage and civil partnership (In relation to unlawful discrimination in employment)
• Socio economic status 

If you decide that the assessment is not relevant to some groups, please say why below. 

The policy is unlikely to be relevant to all equality groups. Stage 3 to be updated by Net Zero Leader (once appointed).

Stage 4. Evidence 

Please consider what evidence is available to help you identify the impact the policy may have on people amongst the relevant groups you have identified? Both quantitative (statistics etc.) and qualitative (event feedback etc.) are equally valid. Please consider a range of sources, including: consultation exercises, surveys, feedback from staff, stakeholders, participants, research reports, Scottish Government Evidence Finder, the views of equality groups, as well your own experience of working in this area etc. 

Remember to consider whether this requires you to consult relevant equality groups. Where it is not possible to gather new information in time to inform the assessment, consider including such actions in your plans to monitor and review the policy.

Additional comments: 

Please Include here any further general comments as supporting evidence, for example, derived from consultation with equality
groups and/or stakeholders etc.

When the Net Zero Action Plan is refreshed in the year 2024-25 consideration will be given to evidence gathering. Evidence will
be completed by the Net Zero Leader (once appointed) when the Net Zero Action Plan is refreshed in the year 2024-25.

Stage 5. The significance of the potential impacts 

Please consider what the evidence tells you about the likely impact (positive or negative) on people sharing a protected characteristic, i.e. how significant could the impacts be if we did not make any adjustments? Remember the duty is also positive – so please identify where the policy offers opportunities to promote equality and/or foster good relations.

Use the following guidance to inform your responses:

Indicate: 

• Where you think that the policy could have a POSITIVE impact on any of the equality groups like promoting equality and equal opportunities or improving relations within equality groups.
• Where you think that the policy could have a NEGATIVE impact on any of the equality groups, i.e. it could disadvantage them.
• Where you think that this policy has a NEUTRAL effect on any of the equality groups listed below i.e. it has no effect currently on equality groups. 

It is important to remember that a policy may be highly relevant to one aspect of equality and not relevant to another.

High impact (The policy or process is very equality relevant)

• There is significant potential for or evidence of adverse impact.
• The policy is institution wide or public facing.
• The policy has consequences for or affects significant numbers of people.
• The policy has the potential to make a significant contribution to promoting equality.

Medium impact (The policy or process is somewhat equality relevant)

• There is some evidence to suggest potential for or evidence of adverse impact.
• The policy is institution wide or cross-Unit, but mainly internal 10 The policy has consequences for or affects some people.
• The policy has the potential to make a contribution to promoting equality.

Low impact (The policy or process might be equality relevant)

• There is little evidence to suggest that the policy could result in adverse impact.
• The policy operates mainly within a Unit.
• The policy has consequences for or affects few people.
• The policy may have the potential to contribute to promoting equality.

Stage 6. Action needed to fulfil the needs of the general equality duty 

Please consider the results of your impact assessment, what mitigating or positive action do you recommend in order to fulfil the three needs of the general equality duty? This will involve considering whether the evidence indicates that there is likely to be a differential impact on particular equality groups, and particularly whether this impact is disproportionately negative. (Differential impact suggests that a particular group has been affected differently by a policy, in either a positive, neutral or negative way).

Remember that it is lawful under the Equality Act to treat people differently in some circumstances, for example taking positive action or putting in place single-sex provision where there is a need for it. It is both lawful and a requirement of the general equality duty to consider if there is a need to treat disabled people differently, including more favourable treatment where necessary. 

Our assessment is that there is no differential impact on particular equality groups for our first Net Zero Plan. The actions we are undertaking in the first plan are largely technical and involve renewable installations across a suite of properties. We suggest that this EqIA is reviews in parallel with our second net zero plan due in 2025.

Needs of the general equality duty

Mitigating or positive actions needed, recommended or planned for each protected characteristic. (Age, Disability, Gender, Race, Sexual orientation, Gender reassignment, Pregnancy and maternity, Religion or belief).

1. Eliminate unlawful discrimination, victimisation or harassment.

   You should consider whether there is evidence to indicate that:

• the policy may result in less favourable treatment for particular groups;
• the policy may give rise to indirect discrimination;
• the policy may give rise to unlawful harassment or victimisation;
• the policy may lead to discrimination arising from disability;
• the policy builds in reasonable adjustments where these may be needed.

2. Advancing equality of opportunity

   You should consider whether it will help you to:

• remove or minimise disadvantage;
• meet the needs of different groups;
• encourage increased participation of particular groups; and
• take account of disabled people’s impairments. 

3. Fostering good relations

   You should consider whether it will help you to:

• tackle prejudice; and
• promote understanding.
   

Stage 7. Taking account of the results of the assessment 

Having considered the potential or actual impacts you should be in a position to make an informed judgement on what should be done. In all cases, document your reasoning that justifies your decision. 
There are four main options you can take:

1. No major change – your assessment demonstrates that the policy is robust. There is no potential for unlawful discrimination and you have taken all opportunities to advance equality of opportunity and foster good relations, subject to continuing monitoring and review.
2. Adjust the policy – this involves taking steps to remove any barriers, to better advance quality or to foster good relations.
3. Continue the policy (despite the potential for adverse impact) – you should clearly set out the justifications for doing this and how you believe the decision is compatible with our obligations under the duty.
4. Stop and remove the policy – if there are adverse effects that are not justified and cannot be mitigated, you should consider stopping the policy altogether. If a policy leads to unlawful discrimination it should be removed or changed.

Option selected: No major change.

Justification: The Net Zero Plan is robust. Further consideration will need to be given the impacts as the Net Zero Plan is refreshed in 2024-25.

Stage 8. Summary of agreed actions resulting from your assessment 

What action, by whom, will be undertaken as a result of the impact assessment?

No action currently, pending refresh of the Net Zero Plan – see below.

Stage 9. Monitoring implementation and review

In this section, explain how you will monitor and evaluate this policy to measure progress on equality issues identified in the EQIA. Include information on when the monitoring and evaluation will take place, and who is responsible for undertaking it. 

This should be part of the regular monitoring and evaluation mechanisms you devise for your policy. This may involve considering:

• What type of information is needed for monitoring and how often will it be analysed?
• How will you engage stakeholders in implementation, monitoring and review?

Review date: The Net Zero Plan is to be refreshed in 2024-25. 

Person responsible: Lead with the Property Services and Net Zero Leader.

Stage 10. Procurement

The public sector equality duty for procurement requires bodies to consider how they can further fulfil the needs of the general duty in how they procure goods and services both through the award criteria and contract conditions. This applies to thresholds which most, if not all, our procurement falls below. However, EHRC guidance encourages public bodies to adopt these principles to help meet our broader obligations in relation to procurement and equality. 

Consequently, if your proposal involves any related procurement of goods, services or advice, you should now consider how best to reflect the results of your impact assessment in the procurement process.

• Award criteria at tender stage
• How will you evaluate award criteria
• Contract performance criteria

Delivery of the Net Zero Plan requires the procurement of goods, services and advice and NatureScot’s procurement team provide advice on this.

Stage 11. Authorisation

Please confirm that: This Equality Impact Assessment has informed the development of this policy: Yes

Opportunities to promote equality in respect of age, disability, sex, pregnancy and maternity, gender reassignment, sexual orientation, race and religion or belief have been considered, i.e.: 

• Eliminating unlawful discrimination, harassment, victimisation;
• Advancing equality of opportunity;
• Fostering good relations

Yes

I am satisfied with the equality impact assessment that has been undertaken for The Net Zero Plan and give my authorisation for the results of this assessment to be published on the NatureScot website.

Name: Stuart MacQuarrie

Position: Deputy Director BS&T

Authorisation date: 16 April 2024

Note: if this EqIA is associated with a policy that requires Director, Management Team or Board sign-off, you should arrange for the results of the assessment to accompany approval of the policy. This is to ensure that decision-makers are given sufficient information to enable them to pay due regard to equality when making their decision.

Stage 12. Storing and publishing this EqIA 

The regulations require that where an assessment has been made and the policy is implemented, the results of any assessment be published ‘within a reasonable period’ of the decision to apply the policy. 

Please save your EqIA to an appropriate folder. For example, if it relates to a project, you should save it to the project folder. Please also record summary information about your EqIA in the quality impact assessment tracker. Send the Objective ID to [email protected] for review and publication on the NatureScot website.

Guidance and tools 

Glossary of key terms 

Equality and Human Rights Commission 

Advance HE (formerly Equality Challenge Unit - ECU)

Equality and Human Rights Commission (EHRC) 

EHRC guidance on public sector equality duty

EHRC guidance on impact assessments