Workplace gender audit evaluation

In December 2021, organisations covered by the Gender Equality Act 2020 (Vic) carried out their first ever workplace gender audit.

For many of these organisations, this was the first time they collected and reported on this type of data. As with many ‘firsts’, there have been challenges and lessons learnt along the way.

To promote continuous improvement, the Commission engaged Allen + Clarke Consulting to conduct an evaluation of our first workplace gender audit process.

In response to Allen + Clarke’s findings, the Commission has initiated a broad range of improvement processes. Key actions include:

• consulting more widely and intensively with our defined entities and key stakeholders regarding changes to the audit data specification in 2023,
• adjusting timelines to plan for a longer gap between the publication of guidelines and the audit submission deadline,
• supporting the establishment and operation of industry-based communities of practice to facilitate targeted communication and peer-to-peer learning, and
• increasing our collaboration and alignment work with other data collection agencies, such as the Victorian Public Sector Commission.

Methodology

The evaluation was undertaken from August to September 2022. It was informed by:

1. A document review of:
   • 30 compliance reports
   • a further key workplace gender audit program documents identified by the Commission, including guidance materials, templates and contextual documents.
2. Stakeholder engagement, including 5 focus groups and 10 interviews across 37 stakeholders made up of:
   • defined entities
   • Commission staff
   • service providers

The results of the document review and stakeholder engagement process were then evaluated against the following 4 key principles found in Better Regulation Victoria’s Guide to Regulation:

1. Supporting duty holders to understand the value of compliance and harm reduction.
2. Supporting duty holders to comply.
3. Targeting regulatory effort based on risk of harm and evaluating efforts.
4. Communicating their impact on regulatory outcomes.

Key findings

The evaluation recognised that the Commission had been tasked with being a catalyst for significant systemic change and that it “…undertook its functions to the best of its ability in difficult and complex circumstances; noting the impact of the coronavirus pandemic, machinery of government changes, and resource and time constraints.”

It made the following 12 key findings on the workplace gender audit process:

1. Defined entities appreciated the importance of the reform the Commission had been tasked to undertake and its efforts to deliver the workplace gender audit process.
2. Compliance reports provided to unengaged defined entities by the Commission fostered more effective participation from those defined entities.
3. The Commission consulted with defined entities on support needs, but this was not generally recognised by defined entities as sufficient.
4. The Commission’s guidance material was accessible and useful.
5. The Commission’s reporting templates were challenging to use.
6. The Commission’s advice and guidance were at times untimely and inconsistent.
7. The Communities of Practice provided an effective support network for defined entities.
8. The regulatory framework meant the Commission could not compel information to be provided in a prescribed form.
9. Data measures collected were useful and valuable for defined entities but some measures could have been further clarified.
10. The Commission’s workplace gender audit requirements were not fit for purpose for some defined entities.
11. The Commission had insufficient time and resources to promote a risk-based workplace gender audit process.
12. Defined entities have made organisational changes in response to the results of their workplace gender audit.

Recommendations

The evaluation delivers 13 recommendations, focused on improving the workplace gender audit process. These include:

1. The Commission should continue to seek input from defined entities as to anticipated support required for the next workplace gender audit.
2. The Commission should continue to tailor the provision of support and materials to promote behaviour change among defined entities and to enhance compliance based on the feedback received in Recommendation 1.
3. Future guidance material from the Commission should include samples and best practice examples from the previous audit.
4. The Commission should encourage defined entities to appoint workplace gender audit executive champions.
5. The Commission should implement measures to provide defined entities with real-time, immediate access to staff at the Commission during the audit period with consideration provided to an instant chatline or a hotline.
6. The Commission should increase investment in the provision of support to defined entities to undertake the workplace gender audit process including consideration of an interactive portal that is a repository for information, that supports material to be uploaded and that enables engagement between defined entities and the Commission.
7. The Commission should publish templates at least six months before workplace gender audits are due.
8. The Commission should continue to work with the Victorian Public Sector Commission (VPSC) and other relevant agencies to streamline and ensure consistency and alignment of reporting processes for defined entities with various regulatory bodies and the People Matter Survey.
9. The Commission should increase communication with defined entities, providing regular notification of when components within the two stages of the workplace gender audit process (preparatory stage and data collection and analysis stage) should be completed to support timeliness and consistency.
10. The Commission, where possible, should promote and support the establishment of Communities of Practice amongst the cohorts of defined entities and establish regular communication between the Commission and defined entities.
11. The Commission should review and document its risk-based approach to the workplace gender audit for internal and external stakeholders
12. The Commission should tailor its guidance materials to align with the diversity and risk profile of defined entities.
13. To support continuous improvement and to streamline and support alignment with other public sector data collection processes, the Commission should implement the data collection framework (developed as an accompaniment to this evaluation report) for future evaluations of the workplace gender audit process.

The evaluation also noted that the resources available to the Commission will always determine the extent of engagement and analysis that it can provide.

Download the full report below.