Equality, Diversity and Inclusion

1. Purpose

Children in alternative provision are more likely than their peers to have experienced exclusion, poverty, unmet special educational needs and prejudice. Our job is to give every learner a fresh start, so we must make sure our own practice does not repeat the unfairness that brought them to us.

This policy sets out how we meet the Equality Act 2010, how we support the Public Sector Equality Duty of commissioning local authorities, and what we do day to day to make Care Cove Alternative Provision fair, accessible and inclusive.

2. Scope

This policy applies to every AP learner, whoever commissions the place, and to parents and carers, staff, volunteers, partner staff, visitors and job applicants. It covers teaching, behaviour responses, therapy, admissions, food, off-site learning, recruitment, employment and the premises at 37 Townhead Street.

3. Law and guidance

• Equality Act 2010. It is unlawful to discriminate directly or indirectly, to harass or to victimise because of a protected characteristic: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. Disabled people must not be treated unfavourably because of something arising from their disability, and there is a duty to make reasonable adjustments.

• Public Sector Equality Duty (section 149). Commissioning local authorities must have due regard to the need to eliminate discrimination, harassment and victimisation, advance equality of opportunity and foster good relations. As a provider they commission, we help them meet that duty.

• Our contracts with commissioning local authorities. We must follow all equality law, including the duty to make reasonable adjustments; follow reasonable equality requirements the commissioning local authority sets; co-operate with it in meeting its equality objectives and equality and diversity statement; take all necessary steps to prevent unlawful discrimination and tell it the steps we have taken; and help it meet its duties under the Human Rights Act 1998.

• Employment Relations Act 1999 (Blacklists) Regulations 2010. We must not act in breach of these regulations.

• Keeping Children Safe in Education 2026 (KCSIE), including the new statutory guidance on gender questioning children, and its links between misogyny and harmful sexual behaviour.

• Relationships, Sex and Health Education statutory guidance (revised, in effect from 1 September 2026).

• SEND Code of Practice 0 to 25 (2015) and the Children and Families Act 2014.

• Worker Protection (Amendment of Equality Act 2010) Act 2023 and Employment Rights Act 2025: the employer's duty to prevent sexual harassment of staff, which requires all reasonable steps from 30 October 2026, and liability for harassment of staff by third parties.

• Employment Rights Act 1996, including the right to request flexible working.

4. Roles and responsibilities

5. Sheffield context and what we do about it

Local data shows that in Sheffield, Black Caribbean and Roma children are disproportionately affected by school exclusion, as are economically disadvantaged children and children with special educational needs and disabilities, and that these gaps have persisted over time. We expect many of our learners to come from these groups, and we act on that.

5.1 Culturally responsive practice

• At the initial meeting, the key mentor learns about the learner's identity, culture, languages, faith and family, and records what matters to them in their plan.

• The curriculum and resources reflect the backgrounds of our learners. The RESET "Food and culture" strand cooks dishes from learners' own families and cultures.

• We work hard with families who have had poor experiences of schools or statutory services: home visits, flexible meeting times, plain language and professional interpreters in the family's preferred language, including Roma community languages. A child is never used to interpret.

• Staff are trained to recognise "adultification" bias, where some children, particularly Black children, are treated as older and less vulnerable than they are. Every learner is seen first as a child who may need protecting.

5.2 Anti-racist practice and challenging prejudice

We name racism and other prejudice when we see it, in learners, adults or systems, including our own. Every prejudice-based incident is recorded and responded to (section 7). Staff challenge stereotypes and low expectations, and the Head of AP checks through supervision and case discussion that decisions are fair.

5.3 Monitoring outcomes by group

We do not exclude, but bias can still show up in how behaviour is handled. Each term the Head of AP analyses, by ethnicity, sex, SEND, disadvantage, looked-after status and English as an additional language:

• attendance and progress against plan targets;

• SEMH and wellbeing measures (Boxall Profile and SDQ);

• Reset time in the regulation space, physical interventions and prejudice-based incidents;

• reintegration, placement endings and destinations;

• complaints and learner and parent voice.

The SWMC reviews the analysis and any disparity leads to a recorded action, owner and date.

5.4 A workforce that reflects the community

Our mentor and learning support posts are recruited from Sheffield residents and advertised openly, on a values-based person specification that does not require prior formal qualifications. Our first recruitment pool is the Dreams Are Real CIC coaching and volunteer network, adults already known and trusted by young people in these communities. Candidates from that network go through exactly the same open, fair process as everyone else (section 11 and the Conflicts of Interest policy).

5.5 Removing the cost of disadvantage

Breakfast and a hot meal are free every attended day, and no child is identifiable as receiving free food. Transport is arranged and paid for where independent travel is not practical. Every learner has library membership, and no learner misses an activity because of cost.

6. Reasonable adjustments and accessibility

We make reasonable adjustments for disabled learners, parents, staff and visitors, and we plan ahead rather than waiting to be asked. For learners with SEND we follow the graduated approach (Plan, Do, Assess, Review) and align targets with any EHCP.

6.1 The premises

37 Townhead Street has three floors, no lift and a step-free rear entrance. During the school day the AP uses all three floors, with therapy and one-to-one learning on the second floor. This creates real barriers for anyone who cannot use stairs.

• An accessibility review against the Equality Act is completed before we start working with learners and is repeated every year, and whenever a learner, staff member or regular visitor has new access needs.

• Before a placement starts, the Head of AP plans any adjustments with the learner and family, for example using ground-floor rooms reached step-free through the rear entrance, adjusting the timetable, or using accessible community venues.

• If we cannot meet a child's access needs, the Director raises it straight away with the commissioning local authority as decision maker. We never refuse a child referred by the commissioning local authority.

• Anyone who may need help to evacuate (learner, staff member or regular visitor) has a personal emergency evacuation plan (PEEP), agreed before they start.

6.2 Communication and environment

• Care Cove Connect is built to WCAG 2.2 AA accessibility standards.

• Letters, plans and policies are available in plain language, easy read, large print or translation on request.

• Low-stimulus regulation spaces support learners with sensory and emotional needs.

• Medical needs are met under the Supporting Medical Needs and Administering Medicines policy.

7. Prejudice-based incidents

A prejudice-based incident is any incident that the person affected, or anyone else, believes was motivated by prejudice or hostility towards a protected characteristic, real or perceived. It includes racist, sexist and misogynistic, homophobic, biphobic, transphobic, disability-related and faith-based language or behaviour, online or offline.

1. Any adult who sees or hears it stops it and makes sure the person affected is safe and supported.

2. It is recorded on Care Cove Connect the same day as a prejudice-based incident, with its type.

3. We respond through the RESET four Rs. The Repair conversation happens the same day, and the learner who caused harm learns why it matters. There is no exclusion.

4. Parents of the learners involved and the referring schools are told the same day.

5. The Head of AP reviews every incident and takes patterns to the weekly multidisciplinary meeting.

6. The DSL is involved where there is child-on-child abuse or sexual harassment (KCSIE Part Five). The police are involved where a hate crime may have been committed and it is in the child's interests. Concerns about extremist views follow the Prevent and Counter-Extremism policy.

7. Prejudice by a member of staff is dealt with under the Staff Code of Conduct and, where a child may have been harmed, the Managing Allegations Against Staff and Low-Level Concerns policy.

8. Curriculum

The Respect pillar of our RESET curriculum teaches managing anger and conflict; healthy relationships, consent and boundaries; misogyny and gender stereotypes; discrimination and the law; rights, police and courts; and what community means. The "Respect and community" block covers citizenship, rights, equality and misogyny. The weekly Respect Circle and the Respect Code ("I respect everyone here") make this a shared habit.

KCSIE 2026 links misogyny to harmful sexual behaviour, and the revised RSHE guidance includes misogyny, AI and deepfakes. Staff challenge misogynistic language and online influencer content, and Tech mastery lessons cover AI-generated imagery. We share RSHE content with parents and agree coverage with each referring school.

9. Religion and belief, diet and prayer

• We respect all faiths and none. A quiet room is available for prayer on request, at times agreed with the Head of AP so supervision and safety are maintained.

• Religious dress and head coverings are welcome, with adjustments only where needed for safety (for example in the vocational workshop).

• During fasting periods, we adjust physical activity and offer a quiet space at lunch.

• Cultural, religious, vegetarian, vegan and medical diets are provided as standard. We confirm with our meal supplier, Food Fusion, how each religious requirement is met and tell families exactly what is served.

• Absence for religious observance is recorded under the commissioning school's or local authority's attendance rules.

10. Sex, gender and gender questioning children

We follow KCSIE 2026 and the statutory guidance on gender questioning children. A child's welfare is paramount.

• Parents are involved as a priority. The only exception is the rare case where involving them would put the child at significant risk of harm. That decision is made by the DSL, recorded with reasons and reviewed.

• No individual member of staff agrees to a request for social transition (such as a change of name or pronouns, or toilet and changing arrangements). The Head of AP and DSL consider any request with the parents, following the guidance, and record the decision.

• We consider the child's wider needs, including SEND, mental health and past trauma, and offer support through their counsellor.

• Every child is protected from bullying and treated with kindness.

11. Staff recruitment and employment

• Fair recruitment. Posts are advertised openly with clear person specifications. Interviews are structured, with a panel of at least two, one trained in safer recruitment. Reasonable adjustments are offered at every stage. Equality monitoring forms are kept separate from shortlisting. A criminal record is not an automatic bar unless the law makes it one; we assess its relevance to the role.

• Equal pay. Pay is set by role, not by who holds it, and men and women are paid equally for equal work.

• Flexible working. Staff can ask for flexible working from their first day. We take every request seriously and respond within two months.

• Harassment. We take all reasonable steps to prevent harassment of staff, including sexual harassment and harassment by parents, visitors or partners. Staff can raise concerns with their manager, the Director or the SWMC Chair.

• Support. We make reasonable adjustments for disabled staff, carry out risk assessments for new and expectant mothers, and support staff through menopause and caring responsibilities.

12. Training

All staff complete equality, diversity and inclusion training by 18 December 2026, or within 8 weeks of joining for anyone who starts later, refreshed every 2 years. It covers the Equality Act, culturally responsive practice, unconscious bias in behaviour decisions, adultification, anti-racist practice, disability and reasonable adjustments, misogyny, the gender questioning guidance and recording prejudice-based incidents. Completion is tracked on the Connect training matrix.

Separately, we offer free expert equality training to employer partners, community organisations and Sheffield schools.

13. Equality information and reporting

• We collect equality information about learners at referral and from families, and voluntary, confidential equality information from staff and applicants. It is handled under the Data Protection, Retention and Information Sharing policy.

• The Head of AP produces the termly analysis in section 5.3 for the SWMC. We never publish figures that could identify a learner; small numbers are combined.

• Each year the Director sets equality objectives for Care Cove AP, approved by the SWMC and aligned with the equality objectives of commissioning local authorities.

• We share our equality analysis, objectives and the steps we have taken to prevent discrimination with commissioning local authorities through contract monitoring, as our contracts require.

14. Complaints

Anyone who feels they have been treated unfairly can complain under our Complaints policy, and learners can use its child-friendly route. Staff can use the grievance procedure or speak to the SWMC Chair. Nobody will be treated badly for raising a concern about discrimination; victimisation is itself unlawful.

15. Monitoring and review

The SWMC reviews equality data termly and this policy every year, or sooner after a serious incident, a change in law or guidance, or a contract change. The Director checks progress against the equality objectives each year and reports it to the SWMC and commissioning local authorities.

16. Related policies

• 01 Safeguarding and Child Protection
• 02 Safer Recruitment
• 03 Managing Allegations Against Staff and Low-Level Concerns
• 05 Prevent and Counter-Extremism
• 07 Behaviour, Rewards and Restorative Practice
• 12 Special Educational Needs and Disabilities (SEND)
• 13 Curriculum, Teaching and Assessment
• 15 Health and Safety, including Fire and First Aid
• 17 Data Protection, Retention and Information Sharing
• 19 Complaints
• 21 Staff Code of Conduct
• 24 Supporting Medical Needs and Administering Medicines
• 25 Food Safety, Allergens and Nutrition
• 29 Anti-Bullying
• 30 Referrals, Admissions and Ending Placements
• 31 Conflicts of Interest
• 36 Accessibility Plan
• 43 Dignity at Work and Preventing Sexual Harassment

Document control and ratification

This policy is signed off by the Designated Safeguarding Lead and the Head of Alternative Provision, and ratified by the Social Work Management Committee. It is reviewed every year, or sooner after an incident or a change in law, statutory guidance or contract requirements, and it is available to any commissioning local authority on request.