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Defined entities will continue to develop and refine their implementation plans to make meaningful progress across the key indicators over the next four years. The following information provides some guidance to support organisations to progress their work by considering intersectionality in ongoing consultation and adapting strategies and measures across key indicators.

  • Once the workplace gender audit data has been analysed using an intersectional approach (described in the section above), organisations should ensure this is appropriately reflected in the GEAP.

    Your workplace gender audit results may reveal insights about people for whom gender inequality may be further compounded by disadvantage or discrimination based on Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other attributes.

    It is important to analyse these results to understand the organisational factors that may cause intersectional gender inequality. These insights will assist in the development of future relevant strategies and measures to address any identified trends, and in a way that is sensitive to the safety, privacy and interests of people who experience intersectional gender inequality.

    It is important to consult with employees who experience intersectional gender inequality or relevant external people or groups about how to outline these insights in a safe and constructive way.

  • You must consult relevant governing bodies, employees, and employee representatives and share the results of your workplace gender audit to understand their perspective, assess the impact of any issues raised and facilitate feedback on proposed actions.

    Consultation can also guide the development of an implementation plan, improving the likelihood of buy-in by impacted employees, for any actions.

    To support intersectional voices to be uplifted in consultations, organisations should:

    • Provide safe spaces for employees to openly share their perspectives confidentially, trusting the processes and people involved, without fear of consequence.
    • Support and leverage staff-led networks for diverse employee groups to ensure employees are aware of consultation opportunities.
    • Share de-identified intersectional data as part of consultations with all groups.
    • At the start of any engagement, clarify the intended use of the information collected and clearly state how the information will be treated.
    • Provide regular progress feedback to the groups who have been engaged to ensure that they are comfortable with how their information is being used and build the mutual trust needed for future engagement.
  • You should state how intersectional gender inequality has been considered in the development of your GEAP. This may be through highlighting:

    • why intersectional gender equality is important for the organisation
    • what your defined entity has identified as the systemic barriers to access, inclusion and equity for people who experience intersectional gender inequality
    • how you consulted with and incorporated feedback from people who experience intersectional gender inequality and any other relevant organisation such as a peak body or representative organisation
    • insights relating to people who experience intersectional gender inequality, identified through your workplace gender audit or through other means
    • strategies and measures relating to intersectional gender inequality in your GEAP
    • how the GEAP complements other strategies and policies in the organisation that relate to other employee attributes, for example a disability inclusion strategy.
  • Insights relating to people who experience intersectional gender inequality, identified through your workplace gender audit or through other means will inform the development of strategies and measures relating to intersectional gender inequality in your GEAP.

    This may include specific strategies or targets for intersectional groups across the workplace gender equality indicators such as:

    • Establish a mentoring program for women of colour (Recruitment and promotion practices in the workplace)
    • Review and improve leave policies for all forms of caring responsibilities (for example, kinship caring) and conduct education with managers to increase awareness (Flexibility, leave and supports for people with family and caring responsibilities)

    Consider if the intersectional issue you are seeking to address is a widespread issue. If so, researching and reviewing strategies that have been effective for other organisations may assist in identifying the best approach.

    Review potential strategies with representative external groups, and employees with intersectional attributes, to understand whether these strategies will be met with engagement, acceptance, or resistance.

    Some employees within a group may require a different, nuanced response, as all employees in a group will not be impacted by, or respond to, an issue in the same way. Consultation will help identify any barriers that may arise in strategy implementation and, determine what mitigating actions or alternate strategies can be taken.

  • Always include people with intersectional attributes on any task force or strategy team addressing intersectional issues related to them.

    Including a wide variety of key influencers with intersectional attributes, that represent different levels, departments, and divisions of your organisation, will ensure that you have a diversity of perspectives. GEAP champions in these groups can also be advocates who promote adoption and acceptance of the strategies developed.

  • Including people with intersectional attributes as stakeholders (both employees and external representative groups) who contributed to the GEAP, will foster trust, and improve re-engagement. Stakeholders who are engaged can help identify lack of progress or community opposition and assist to adjust course in the roll-out of the strategy. Sharing progress with these stakeholders will also promote accountability and action from the implementers of the strategy.

    Consider how implementation and impact of intersectional strategies will be measured, including a combination of quantitative and qualitative data.



Amanda calls for senior leaders to succession plan and promote Aboriginal and Torres Strait Islander women into their roles within the next 5 years.

Heather discusses how identified gaps, for example where older women are being excluded, should be addressed with actionable plans.

Nevena suggests better training for HR staff on how to handle harassment complaints from trans and gender diverse women.

Case study

Read how this defined entity, responsible for urban planning, followed the 6-step process to complete their GEAP and how they worked through their Gender Equality Audit Data.

  • Background

    This defined entity is responsible for urban planning and has over 200 employees. This defined entity’s purpose is to deliver a healthy environment that supports a liveable and thriving Victoria. They have formed a project team to deliver on the obligations of the Act. The team has named this work “The Gender Equality Project”. They have briefed staff that this project offers an understanding of the barriers to diversity and inclusion and will use this understanding to introduce meaningful actions to address gender inequities for all staff. They have shared that the project’s products seek to address the impact this has on women’s career advancement, economic security and job satisfaction. Early staff consultations revealed that staff felt strongly that the needs of women with regards to Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other attributes needed attention, as this had not been done in the entity’s history. The project team agreed that this was a critical need and it aligned with the Gender Equality Act guidance.

    The project team has outlined four (4) phases of work (see below) and are up to phase three (3): Consultation with stakeholders to develop the GEAP.

    Phase 1 – Planning

    • confirm objectives, timing and scope of work
    • develop a project plan including agreed timeline of deliverables
    • collaborate with key stakeholders to understand data gaps
    • collect any relevant organisational materials/resources to support the project (this defined entity used the gender equality principles, as outlined by the Gender Equality Commission) to link their documentation and messaging.
    • develop a communication plan
    • communicate with key stakeholders regarding project process
    • develop and facilitate short sharp training to improve capability of key stakeholders.

    Phase 2 – Prepare Gender Audit including analysis

    • gain support from internal departments to develop a privacy assessment and protocols
    • obtain data collection and extraction support
    • secure resources for data cleaning and meaningful data analysis of workforce and employee experiences
    • prepare audit outcomes report.

    Phase 3 – Conduct stakeholder consultation and develop GEAP

    • set up and facilitate consultation activities, including workshops or surveys
    • collate, synthesise and document outcomes to support the development of GEAP.

    Phase 4 – Develop Gender Impact Assessment Framework (or similar) and tools and training to build employee capability

    • partner with key resources to help in the build of a GIA framework or process
    • develop and facilitate GIA user capability training
    • design GIA process support resources to help upskill employees.

    Challenge and Complications

    The defined entity had a gender equality strategy and the initial assumption was that this strategy would be updated with the workplace gender audit data inputs, analysis and insights to form the GEAP.

    However, the workplace gender audit has revealed some surprising and different results, as this was the first time that data collection was done intersectionally, to understand the lived experience of Aboriginal and Torres Strait Islander women, women of colour, women with a disability, women across different ages, religions, faiths, sexualities and gender diversities.

    As a result of the focus groups that were conducted with Aboriginal and Torres Strait Islander women and women of colour for this data collection process - women have for the first time become vocal about their lived experience of being minorities in the workforce, experiencing slow career mobility.

    • Muslim women have shared that there has been a lack of suitable prayer rooms and understanding of Islamic faith and practices, especially during Ramadan.
    • Shortly after focus groups were conducted, there have been two complaints of bullying and harassment lodged, linked to racism; one internally and one to the Union. These are the first of these types of complaints that this defined entity has had to deal with.


    The project team followed the 6 steps process to complete their GEAP, as outlined by the Gender Equality Commission guidelines, however were successful in completing Steps 1, 2 and part of step 3, with a view to completing the rest within the next 2 months, with further in depth consultations.

    With regards to building in the workplace gender audit input and having meaningful consultation and engagement (Steps 1 & 2):

    • The project and senior leadership team met to discuss the initial analysis of the workplace gender audit and the two complaints. They agreed that the duty of care of the complainants was of the utmost importance in the light of the work on the Gender Equality Project’s purpose and the Act.
    • The project team members, many of them with lived experience, being women of colour, highlighted that the complaints process should also be assessed as part of the actions within the GEAP. These women also raised that any potentially personal, identifying information needed to be removed to protect women’s privacy and confidentiality (especially Muslim women), but that the intersectional barriers shared needed to be included in the GEAP.
    • The group also identified that the intersectional attributes needed to be included in the defined entity’s people systems for easier future data collection.
    • The defined entity’s data analytics team also shared that the ABS statistics utilised to understand Victoria’s diverse population needed to be included in the GEAP, as this data guided the thinking for the GEA and the upcoming GIA.
    • Another document earmarked to be included in the GEAP submission was the project team’s communication plan, which included Board presentations, regular staff and union consultations.

    With the case for change (step 3), the PR and Communications team compiled a history of the defined entity’s past efforts to achieve gender equality. They also made the link to the gender equality principles in their phase 1 planning process. Their case for change documentation linked their purpose of ‘delivering a healthy environment that supports a liveable and thriving Victoria’ specifically to the following principles:

    • all Victorians should live in a safe and equal society, have access to equal power, resources and opportunities and be treated with dignity, respect and fairness
    • gender equality benefits all Victorians regardless of gender
    • gender equality brings significant economic, social and health benefits for Victoria
    • advancing gender equality is a shared responsibility across the Victorian community
    • gender equality is a human right and precondition to social justice.


    The project team and the senior leadership team have achieved a draft GEAP utilising the output of the GEA, including a focus on intersectionality. While there is significant work to complete to get the GEAP ready for submission, there is buy-in and support from the Board, senior leaders and staff that this work is providing meaningful understanding and actions to address gender inequities that will improve everyone’s work experience. The project team agreed to include the following activities within the GEAP, that addresses issues raised through their audit results:

    • The established Women in Leadership Staff Led Network to include women with intersectional attributes, especially women of colour who experienced downward career mobility.
    • HR staff to receive training on responding, investigating and managing racism complaints.
    • A Calendar of Days/Weeks of significance like IDAHOBIT Day, Pride Week, NAIDOC Week, Cultural Diversity Week will be curated and observed as a way to build awareness and education and promote intersectionality.
    • All physical spaces to be designed with an intersectional lens (unisex bathrooms, chest feeding rooms, prayer rooms).

    Next Steps

    The PR and communications team are working closely with the project team on writing a vision statement (part of step 3) for what gender equality would look to look like for their organisation in four years. They are utilising the GEA analysis, the gender equality principles and indicators, as well as how the organisation plans to meet gaps relating to Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and/or any other attribute. A draft statement will be formulated for approval by the Board and senior leadership team. This will need to go through several consultations before it is approved. There will also be a Townhall held, virtually, to share what this vision looks like.

    The HR representatives on the project team are working through all the strategies and measures relating to pay, sexual harassment, recruitment and promotion practises, terms, conditions and practices related to family violence leave, flexible working arrangements, carers leave. They are focussing on the intersectional impacts that were derived from the GEA data on these existing practices and policies, but also the critical insight revealed of work occupation segregation and composition for women of colour and women with a disability. (Step 4).

    Leaders are currently being engaged on how the continuous development of the GEAP and implementation of the plans will be resourced. The project team was an interim team put together to achieve the deliverables for 2021, until mid 2022. (Step 5).

    A sub-group of the project team (made up of reporting experts) are specifically working on how progress on the GEAP will be tracked, communicated and written in a timely manner, to align with other strategic reporting internally, to the Board and publicly. Key templates are being designed to make the tracking, reporting and communicating easier year on year (Step 6).

Reviewed 23 November 2022

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