ILH DIVERSITY POLICY

ILH DIVERSITY POLICY

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

MANAGEMENT

ILH DIVERSITY POLICY

Contents
1

Purpose ...................................................................................................................................... 2

Application ................................................................................................................................. 2

Interaction with other Policies .................................................................................................... 2

The Use of Certain Terms ........................................................................................................... 3

Policy Statement ........................................................................................................................ 4

Objectives .................................................................................................................................. 6

Implementation of the ILH Diversity Policy ................................................................................. 7

Measurable Objectives to be set by ILH to 30 June 2016 ........................................................... 10

Summary .................................................................................................................................. 11

10 Policy Review ........................................................................................................................... 11

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 1 of 11

MANAGEMENT

ILH DIVERSITY POLICY

1.

Purpose

1.1

Integrated Legal Holdings Limited ABN 20 120 394 194 and its subsidiaries (ILH) recognises,
respects and values the diversity of its staff and the general ILH community. ILH recognises
the benefits of diversity where people of different genders and from different backgrounds
can bring fresh ideas and perceptions which may create new products and services, may
make the way work is carried out more efficient and may increase the value of existing
products and services. It is for these reasons that ILH has formulated the ILH Diversity Policy
(the Policy).

1.2

ILH is committed to sound diversity practices in its legal services and allied business under
the Policy by providing a diversity inclusive workplace in which everyone has the opportunity
to fully participate and is valued for their distinctive skills, experiences and perspectives.

2.

Application

2.1

The Policy applies to all staff, the Board of Directors and other members of the ILH community
such as bona fide visitors.

3.

Interaction with other Policies

3.1

This policy operates in conjunction with other ILH policies, including:

a)

The Workplace Grievance and Complaint Policy;

b)

The Behaviour and Culture Policy; and

c)

The Whistleblower Policy.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 2 of 11

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ILH DIVERSITY POLICY

4.

The Use of Certain Terms

4.1

The Policy makes reference to certain terms which are summarised below:
a)

Cultural and Linguistic Diversity

Refers to diverse language and cultural backgrounds which frequently parallel diverse
ways of thinking. This may offer access and insight into new operational methods and
client networks. From the perspective of clients, competence in languages other than
English may be an indication of service excellence.

b)

Cultural Diversity

c)

Means cultural differences based on race, colour, political or religious conviction,

language and national or ethnic origin. The term embraces both Indigenous Australian
and multicultural perspectives. (As well as valuing and promoting cultural richness within
ILH, this aims to redress any unfair, unjust or illegal practices which may result directly or
indirectly from a person's cultural difference, identity and/or context.)
Diversity
In the ILH context includes the variety of backgrounds, characteristics, beliefs, attitudes,
languages and social circumstances, sexual orientation, gender history and age of staff,
who work and interact at ILH. Valuing diversity results in an harmonious environment
that embraces and supports diverse contributions and perspectives.

d)

Inclusive Language
Is free of bias and discrimination and avoids stereotyping and false assumptions about
people on the basis of their: sex; marital status; pregnancy or potential pregnancy; breast
feeding; sexual orientation; gender history; race; nationality; colour or ethnic origin; age;
religious or political conviction; impairment or disability; family responsibility or family
status. Inclusive language allows an all-encompassing discourse and a multiplicity of
perspectives.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 3 of 11

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ILH DIVERSITY POLICY

5.

Policy Statement

5.1

Valuing and managing diversity means that ILH will:

a)

Facilitate equal employment opportunities based on relative ability, performance or

potential;

b)

Actively promote diversity in the sourcing of candidates for employment;

c)

Help to build a safe work environment by taking action against inappropriate workplace
and business behaviour that does not value diversity including discrimination,
harassment, bullying, victimisation and vilification;

d)

Develop flexible work practices to meet the differing needs of employees provided that
the implementation of these practices is congruent with effective practices for the
business;

e)

Attract and retain a skilled and diverse workforce as an employer of choice;

f)

Enhance customer service and market reputation through a workforce that respects and
reflects the diversity of ILHs clients;

g)

Actively provide opportunities for employees to further their learning and development
potential;

h)

Make a contribution to the economic, social and educational well-being of the

communities it serves;

i)

Improve the quality of decision-making, productivity and teamwork;

j)

Develop Senior Executives and Board Members;

k)

Meet the relevant requirements of legislation and regulation in relation to gender and
other diversity and regularly report to the ILH Board of Directors in relation to status of
same;

l)

Record and report the participation and level of men and women in the ILH workplace to
the ILH Board of Directors for inclusion in the Annual Report in a manner that is accurate
and not misleading;

m)

Disclose in each Annual Report the proportion of women employees in the whole
organisation, women in senior executive positions and women on the Board of Directors;

n)

Identify programs that assist in the development of a broader pool of skilled and
experienced Board candidates including initiatives focused on skills development such as
executive mentoring programs or more targeted practices relating to career
advancement such as those that develop skills and experience that prepare employees
for senior management and board positions; and

o)

Create an inclusive workplace culture where Management seeks employees input and
ideas and everyone feels they can make a meaningful contribution.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 4 of 11

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5.2

ILH DIVERSITY POLICY

In order to achieve the above matters under the Policy, all areas of ILH will continually develop
and adapt an ILH culture which integrates the following into their policies, procedures, practices
and management processes:
a)

b)

Employment

Attract and retain people from equal employment opportunity target groups,
youth and mature age workers and others who together make up a diverse
workforce.

Ensure that employment practices in the areas of recruitment and selection,

induction, training and staff development promote a workforce which has cultural
and linguistic diversity up to at least the level at which people from diverse
backgrounds are represented in the population of Australia.

Provide appropriate training to staff who are from diverse backgrounds and
genders to enhance the retention of new employees and promotion of existing
employees' career development.

Ensure that managers and staff attend programs to enhance sensitivity and
communication using inclusive language to increase awareness of issues in relation
to the employment of staff from diverse backgrounds.

Provide support for special needs of staff (for example, language support,
workplace modification) provided that this does not result in unjustifiable hardship
for ILH or its member firms.

Embrace the ideas of the people who will shape the future as a powerful way to
sustain corporate relevance;

Preserve the collective wisdom of the organisation and using the experience of
senior staff manage a balance between workers from each end of the age
spectrum.

Decision Making

Ensure that decisions made by and for ILH incorporate input from staff from
diverse backgrounds and genders.

Ensure that, other than in exceptional circumstances, committee meetings shall be

held at times which will not disadvantage people with family responsibilities and
those who work part-time.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 5 of 11

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c)

ILH DIVERSITY POLICY

Workplace Culture

Ensure that individuals have the right to express their ideas, theories, and opinions
while respecting the rights of others without fear of discrimination, harassment or
bullying and irrespective of gender.

Ensure that relations between staff are respectful of diversity and free of
behaviour of a racist, sexist or otherwise prejudicial or demeaning kind. Staff
should be sensitive to the needs of staff from other cultures, particularly those
whose first language is not English.

Make reasonable provisions for the cultural and religious needs of staff. Where
appropriate, approve access to flexible work arrangements.

6.

Objectives

6.1

To provide a diverse, flexible and creative work environment in which ILH actively acknowledges,
supports, encourages and values diversity, including gender diversity.

6.2

To provide structures and policies to create a culture for ILH that is cosmopolitan and diverse,
resulting in an attractive, vibrant and intellectually stimulating work environment.

6.3

To promote and encourage an ILH culture where all staff ensure that their behaviour is ethical.
That is, behaviour that acknowledges and protects principles of fair representation and just
dealings among all its members.

6.4

To promote an environment where the linguistic and cultural diversity and other skills and
talents of all staff and of the ILH community contribute to the goals of the company.

6.5

To further develop ILH locally, nationally and internationally as a leader in the area of harmonious
and creative diversity in the workplace.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

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ILH DIVERSITY POLICY

7.

Implementation of the ILH Diversity Policy

7.1

Introduction
a)

ILH has developed a diversity policy in accordance with good corporate governance
practice. This paper sets out some of the matters which need to be considered for the
successful implementation of the diversity policy and some of the tasks required to be
carried out to ensure an effective diversity program is put in place for the organisation.

b)

For successful development of a workplace diversity program at ILH, it is beneficial to

gather information to assess the current position of ILH. Relevant information might
include:

c)

revisiting corporate and business plans;

a demographic profile of employees, including a demographic profile of designated

groups, a skills analysis and the particular need of staff at ILH;

any external factors which will affect ILH during the program. These could include
trends and issues which are expected to impact on ILH (such as composition of the
labour market, technological advances, stakeholder and community pressures);

assessment of the prevailing culture and business requirements of ILH;

reviewing previous Equal Employment Opportunity (EEO) performance;

existing human resource policies and practices; for example, recruitment and
selection practices, anti-harassment strategies and performance management
schemes to identify any barriers or gaps.

Information gathering and analysis should enable a clear picture of ILH to emerge. In
particular:

baseline statistical data about ILH staff;

policies and practices that inhibit the management of a diverse workforce;

practices that prevent innovative policy making and better customer service;

opportunities for improving, enhancing or extending existing ways of doing things

or finding new ways of doing them;

benchmark targets identified that have been identified in the process;

appropriateness and effectiveness of existing EEO, anti-discrimination and diversity

strategies; and

business needs and issues.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 7 of 11

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7.2

ILH DIVERSITY POLICY

Identification of desired outcomes

a)

Outcomes could include:

awareness of, and commitment to, workplace diversity principles;

recognition of the positive value of a diverse workforce to the company;

integration of workplace diversity principles in business and human resources

practices and systems;

creation of a harmonious and supportive work environment; and

Even though strategies will vary, at a minimum they should cover:

-

b)

c)

prevention of discrimination and unfair treatment;

valuing and utilising the diversity of employees;
balancing work and family responsibilities;
eliminating employment-related disadvantage on the basis of gender, race,
disability, sexuality, age, linguistic or cultural background, or being an
indigenous Australian.

Documentation of the strategy should:

set out a statement of legislative and Government policy objectives for the
workplace diversity program;

set out how workplace diversity will support ILHs business objectives;

identify expected benefits to ILH including qualitative benefits such as increased

ILH performance through increased staff morale; and

identify projects and actions to be implemented as part of the workplace diversity

strategy.

Performance indicators for each strategy should also be developed. It is best if they
are simple and easy to measure and that there is a transparent process for monitoring
and evaluating the indicators.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 8 of 11

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7.3

ILH DIVERSITY POLICY

Implementation of best practice

In the implementation of an effective diversity policy within ILH the following factors need to
be considered and where appropriate implemented:
a)

b)

c)

d)

Planning

Diversity measures are integrated with existing accountability processes, for

example performance management.

Performance indicators are based on information gathered during the planning

phase.

Diversity program is revised in response to annual evaluation and results of

monitoring.

Senior management demonstrate a commitment to the program.

Implementation and Monitoring

Program is communicated to staff who are encouraged to discuss and respond.

Resources to support implementation are provided throughout ILH.

Mechanisms are in place to ensure regular monitoring.

Implementation of the program is adjusted to account for the outcomes of

monitoring.

A range of measures to recruit and support staff in designated groups is

implemented.

Evaluation

A range of data is regularly collected, including reliable information on the staff

profile of ILH.

Information is evaluated with comparison to other financial services entities in the

sector.

Information of the current position is compared to data gathered at the inception

of the program.

Progress toward diversity outcomes is demonstrated by the data.

Reporting

Reporting highlights improvements and challenges.

Monitoring and evaluation results are used in reporting.

Comprehensive reporting is provided in ILH annual report.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 9 of 11

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ILH DIVERSITY POLICY

8.

Measurable Objectives to be set by ILH to 30 June 2016

8.1

It is recommended the following measurable objectives be set for ILH Limited:

a)

Female representation on the Board/Senior Executive level/company-wide of 50% by

30 June 2016.

b)

Set clear expectations of behaviours which foster and promote diversity, inclusion and
flexibility and evaluate employees on these behaviours as part of their annual
performance review.

c)

Implement a leadership program which assists in the development of a diverse pool of

skilled and experienced executives and that prepares them for senior management board
positions.

d)

Implement a program to reduce the attrition rates of female employees identified as top
talent.

e)

Implement recruitment practices which aim for a mix of males and females of varied
cultural and ethnic backgrounds short-listed for board positions or senior executive roles.

f)

Conduct a gender pay audit and implement equal pay by 30 June 2016.

The following is an extract from the 2011 ILH Annual Report

8.2

Diversity Policy
The company values diversity and recognises the benefits it can bring to the organisations
ability to achieve its goals. Accordingly the company has developed a diversity policy, a copy
of which can be found on the company website. This policy outlines the companys diversity
objectives in relation to gender, age, cultural background and ethnicity. It includes
requirements for the Board to establish measurable objectives for achieving diversity, and for
the Board to assess annually both the objectives, and the companys progress in achieving
them.
In accordance with this policy and ASX Corporate Governance Principles, the Board has
established the following objectives in relation to gender diversity. The aim is to achieve
these objectives over the coming five years as director and senior executive positions
become vacant and appropriately skilled candidates are available:

Number
127

%
71%

Objective
30/06/2016
%
40-60%

28%

40-60%

1
1

7%
33%

40-60%
40-60%

Actual as at 30/06/2011
Number of women employees in the whole organisation
Number of women Principals and in senior executive
positions
Number of women on member firms Boards
Number of women on ILH Board
Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 10 of 11

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ILH DIVERSITY POLICY

9.

Summary

9.1

In summary, this paper is a submission to the Board of ILH of the matters which need to be
considered in the development of a diversity program for the implementation of the ILH
Diversity Policy. It is a requirement of the ASX Corporate Governance Principles that
measurable objectives be set and the program to be put in place by ILH on or before 30 June
2012.

10. Policy Review

10.1

This policy is reviewed every at least annually to ascertain whether any changes are
required.

Issued By:

Company Secretary

Policy Owner:

ILH Board

Issue Date:

20 December 2012

Page 11 of 11