The review, published on 3 April, was commissioned in October 2024 after an employment tribunal found that three white police officers who worked at the force were prevented from applying for a detective inspector role in 2022, after a superintendent was told to help improve diversity by appointing a sergeant from an Asian background to the rank of detective.
Kerrin Wilson, a retired chief constable of Lincolnshire Police, conducted the report, which was established to determine the mistakes that led to Thames Valley Police losing the tribunal.
According to Wilson's findings, the force's 'positive action progression programme', which aimed to encourage the progression and retention of members of underrepresented groups, led to some employees feeling excluded. She made 51 recommendations indented to help the force to improve.
Police and crime commissioner Matthew Barber, who commissioned the review, stated: “There was a lack of consistency, information and inclusion in the way policies were applied, leaving parts of the organisation feeling left out and overlooked.”
This case acts as a reminder that treating diversity targets as a tick-box exercise doesn’t work, according to Kimberley Rowbottom, HR director at employee benefits provider Pluxee.
She told HR magazine: “When organisations rush to meet diversity targets without proper consultation and transparency, it can create division rather than unity.
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“For diversity policies to work, you need to bring everyone on the journey with you. That means open conversations across the organisation about the ‘why’ behind these initiatives, and transparency around how decisions are made. If people feel left out or overlooked, even the best-intentioned policies can end up dividing and causing upset.”
Nick Henderson-Mayo, director of learning and content at eLearning software provider VinciWorks echoed this, emphasising that diversity policies should be designed in line with the people that they will benefit the most.
Speaking to HR magazine, he said: “Just as data protection officers rigorously assess new data practices, our diversity policies must undergo the same scrutiny. Our policies shouldn’t be copied and pasted from lobby groups, but designed in partnership with staff, managers, and legal and compliance. Only by aligning diversity practices, policies and training with the law itself can we ensure their longevity, consistency and impact.
“The answer is not to shut down diversity, equity and inclusion (DEI) nor double-down with some form of ‘resistance,’ but to bring DEI back into the fold of compliance. We need the dispassionate analysis of our legal and compliance teams to take a serious look at how diversity and inclusion initiatives are being delivered, and answer one simple question: is it compliant with the law?”
Barber stated: “Due regard should be given to all staff. A wide range of recommendations focus on key areas of central oversight, training, better alignment with relevant bodies, internal communications, internal recruitment and career advancement programmes. These, if implemented, will go a long way to address the issues identified."
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HR leaders and employers should aim to make sure that diversity policies engage the entire workforce, Richard Dickins, managing director at social change consultancy Social Value Business, added.
Dickins told HR magazine: “In our experience, many organisations issue diversity and inclusion policies without fully engaging the workforce. True culture change requires a detailed understanding of the issues faced by employees, backed up by measurable commitments and action planning.
"It's essential to build a full understanding of the staff and candidate experience without jumping to solutions or making assumptions. Often, diversity can be a tricky or sensitive subject, so it's worth engaging with charities who specialise and who can run in-house or community-based workshops, creating a safe, independent space for people to speak up.”
Dickins added that anonymous surveys can be a useful tool in fully understanding the issues and challenges that employees face.
If diversity and inclusion efforts go wrong, HR's first call should be to legal and compliance, stated Henderson-Mayo.
He said: “If someone feels excluded from a diversity programme, then it is not doing the job of inclusion. Employees who raise concerns must be listened to. If not, they’ll be heard in the courts."
It is essential for employers to take ownership if a complaint is made, added Dickins. He said: “By taking swift, decisive actions that are peer-reviewed and informed by established best practice, organisations can help preserve their legitimacy and reputation.
“Effective communication helps rebuild trust and influence change. Employers must then promote honesty, transparency and commit to future scrutiny."
Thames Valley Police chief constable Jason Hogg told the BBC: "[The force] takes these recommendations seriously and will use them as it seeks to improve. I am also pleased that the report recognises that Thames Valley Police is an organisation that has wonderful people with passion and ways of working that deliver excellent policing for its communities and that the force is effective in tackling crime and supporting those most vulnerable."
