Behaviours Framework

Behaviours Framework

05/11/2024

Pam Moran – Senior Business Consultant – Organisational Development

Catherine Cunningham – Head of Organisational Development

Yes, but not required. It’s an internal guidance document and doesn’t contain any personal or highly sensitive information.

This framework is part of our drive for continuous improvement and supports our new People Strategy launched at the same time at the end of November 2024.

The introduction of values across SEPA was a collaborative and data driven approach. We used an industry leading creative agency to develop the values and design the creative options. Their initial work also provided the foundation for our behaviour’s framework, with a continuous focus on inclusivity in approach and language which is reflected in the framework for use by all SEPA colleagues.

SEPA’s Equality Outcomes 2022-2026

· Outcome 1 – We have increased the number of people from currently underrepresented groups in our applicants, our staff and those who progress within the organisation.

· Outcome 2 – People with lived experience of inequality, related to a protected characteristic or socioeconomic status, access and use SEPA’s services without barriers.

· Outcome 3 – Staff with lived experience of inequality and barriers, and with a wide variety of needs, feel listened to and respected as SEPA meets those needs.

· Outcome 4 – We have decreased our gender pay gap and occupational segregation related to gender, disability, and ethnicity.

Outcome 1

The behaviours support our core values and will be integral to the way in which we all deliver our work. This is part of our drive for continuous improvement and aim to recruit, develop and retain diverse talent. As we move to streamline and improve our recruitment processes it will help to ensure that our processes are fair and are not just driven by experience but also factor in our values and behaviours (i.e. ‘how’ we deliver our work). How we deliver our work is as important as what we deliver.

Outcome 2

The framework has been developed to reflect what behaviours are required to deliver our work. It guides us how we interact with one another as colleagues as well as how we interact with our external partners and stakeholders to ensure that we work with them in a way that is always professional including the need to be respectful of others at all times.

We know that our colleagues are dedicated to doing amazing work to support and protect the environment. We are all purposeful, professional and passionate. The behaviours framework is about having a model of approach that we can all use as a reference point to help and support one another to be the best version of ourselves. How we process information, think and act can vary. How we are able to interpret show and understand what ‘good’ looks like can vary. The framework helps us all have a common focus to build that understanding across SEPA and encourage open positive interaction and discussion about what will help us to thrive so we can be more effective, equitable and inclusive, using the framework to help consciously guide us in our thinking and our actions. The framework has been developed with this in mind and is not intended to offset or in any way downsize the great work that we do or positive roles that we play in being ambassadors for environmental protection.

Outcome 3

The framework will set the direction on how SEPA expects colleagues to behave in the delivery of their work and their interactions with peers and stakeholders. It takes account of colleague feedback on what behaviours are required to help people feel valued, heard and respected to perform at their best. This feedback has been built from cross organisational discussions and engagement about our values, pre and post launch.

Outcome 4

It won’t directly support this outcome but may do so indirectly.

It will not affect the work of teams and functions; however, it will influence how we interact and support each other in our day-to-day work.

The impetus behind the framework has been the development of our values. Our three core values (purposeful, professional and passionate) are being used to create an inclusive working environment where all colleagues feel valued, supported and respected and where their health and wellbeing is uppermost.

As well as outlining the expected behaviours from all SEPA colleagues, it provides a means to ensure that we are all treating each other with dignity and respect and a means to challenge behaviours which work against this and could be construed as discriminatory. It will therefore act as a formal tool with which to manage and support colleagues and help us to work in a healthy and positive environment where everyone is more aware of how they interact and what ‘good’ behaviour looks like.

• All SEPA Colleagues - There has already been cross organisational engagement through the development of our core values earlier in 2024. The content of the behaviour’s framework was also built from cross organisational conversations and feedback from colleagues in our values workshops which ran over the course of May and June 2024 in person and on MS teams to ensure accessibility.

• Following approval by CLT, the behaviour framework will be communicated to all colleagues as part of our People Strategy launch. A communications plan will be developed to help buy in and embedding of the framework. As the framework will be key resource it will be subject to regular review.

• All Managers – the framework provides clear and easy to follow positive indicators of leadership behaviours and next steps for managers. Following approval by CLT, the framework will be communicated to all colleagues (including managers) and workshops

will be organised for managers to discuss their role and how to use the framework with their teams.

• HR have also been instrumental in the development of the framework as this will be a key tool with which HR will support managers, team and individual performance across the organisation. HR and OD will work together to roll out a series of managerial workshops in Q1 2025.

• The Board and the CLT have fed into it to ensure that the pitch and content reflects our identity and the culture we are trying to build.

• EDI – content will be reviewed by Senior Consultant EDI and our Equalities working group to ensure that it is inclusive.

• The JNCC - the framework will also be shared and discussed with our Union.

Evidence for change was sought through internal survey and a series of values driven internal workshops (over Q2 and Q3 2024) for people managers and wider colleagues to ensure a wide range of feedback and insight into what the values mean and how they manifest themselves in our behaviours. Those conversations directly fed into the content of the framework.

Discussions from colleague values workshops also indicated a requirement for a behaviours framework to support the values.

There were initial discussions with the CLT and PWD portfolio management team to agree the rationale for a behaviour framework

Benchmarking of other organisational behaviour frameworks

Discussions with HR to ensure the framework will add value to their work in supporting managers and their teams across the business.

Discussions with the senior PWD managers and the wider portfolio to ensure the nature and content of it fed into and aligned with work planned and under way

The Equality Act 2010 places a duty on public bodies to prevent discrimination in all aspects of service provision. It provides a clear and positive legal duty to eliminate discrimination and to ensure equality of opportunity and good relations between different groups. See table for the three needs of the general duty for each Protected Characteristic in turn. 

•    Eliminate unlawful conduct
•    Advance equality of opportunity
•    Foster good relations

The public sector equality duty requires us to consider or think about how our policies or decisions affect people who are protected under the Equality Act. The framework sets out clearly ‘how’ we expect SEPA colleagues to deliver their work. This is therefore fundamental to the way in which colleagues deliver our services to our stakeholders and the communities we protect and serve.

The behaviour Framework sets out examples of the positive standards of behaviours to deliver our roles. These reflect the values, aspirations and standards of SEPA to be purposeful, professional and passionate and support the delivery of our corporate priorities.

We are clear when it comes to our value of being Professional within our behaviour framework that we expect all colleagues to show that “they treat others with dignity and respect”. We ask that all leaders “actively champion honesty, fairness, respect and inclusivity” and that they “role model the behaviours required for an inclusive workplace, ensuring the safety and wellbeing of my team and others” We also ask colleagues to build “open and trusting” relationships with our key stakeholders.

Our recruitment process will encompass our values and behaviours and together these will develop and enhance these procedures which are already monitored to ensure that there is no discrimination.

The values and behaviours are an intrinsic part of the employee lifecycle and will work to enhance colleague experience and procedures which support L&D, career development, performance management, reward and recognition and moving on. We already adopt a hybrid working model and offer excellent flexibility to all colleagues through our benefits. Our behaviours will become part of who we are and ensure that we all treat each other with dignity and respect irrespective of individual differences.

The content of the framework is such that it promotes and strives to maintain a positive culture of respect for all colleagues, partners & stakeholders to feel valued as individuals so they can give their best and participate in and use our services. We embrace the values & benefits of a diverse living and working environment. Colleagues should feel valued as individuals and able to give their best in a safe environment working effectively, competently and confidently and reflect the communities we serve and protect and enable them to engage in our services.

The behaviours framework is designed to help embed a culture that builds engaged, effective relationships with managers and their individual team members, protecting all employees from discrimination and ensuring that we challenge and hold each other to account for behaving in ways which are always respectful and inclusive.
The framework will be applied equally to all employees regardless of their age, disability, gender reassignment and gender identity, pregnancy and maternity, race and ethnicity, religion or belief, sex, or sexual orientation.
•    In the 2023 Equality and Mainstreaming Report, we reported that of 1210 colleagues the majority of our people (439) were in the 45-54 age bracket. A further 298 were aged 55 and above.
•    As of 2023, SEPA recorded that 2.48% of colleagues recorded a disability.
•    As of 2023, 48.35% of SEPA colleagues are married or in a civil partnership.
•    In 2023, we reported that of 1210 colleagues, 30 are black, Asian, mixed, other. 589 are white Scottish, 324 are white British, 99 are white other with 168 colleagues where information was not provided.

•    In 2023, of 1210 colleagues 91 are Roman Catholic, 207 Church of Scotland, 70 are other, 528 are none and 314 prefer not to say.

•    As reported in 2023, SEPA has 519 male colleagues and 691 female colleagues. Of these, 5.01% of males are part time and 25.90% of females are part time.

Existing lived experience/Equality, Diversity and Inclusion working groups to ensure the language is appropriate and inclusive.

A well-considered structured roll out of our behaviours over the coming months will help solidify the expectations on ‘how’ we deliver our work in a way that respects individual differences and encourages and supports individuals to perform at their best.
Further engagement through surveys and focus groups as part of a test and learn/continuous improvement approach will help us to ensure that our approach is inclusive and does not work to discriminate or disadvantage SEPA colleagues.
EDI is an integral part of SEPA. Our work is supported by a mainstreaming equalities report and lived experience groups to ensure that our policies, programmes and practices do not exclude or disadvantage any individuals. For example, we have LGBT+ training and relationships with the Equality Networks. The Behaviours Framework could help challenge poor behaviours and empower those with this protected characteristic to raise issues in confidence when they occur.

No.
The behaviours support our values and underpin the People Strategy which together work to support a healthy and positive working environment for all people.

In designing the framework and creatives inclusivity and accessibility was at the forefront of thinking. Text was written with the user in mind, making sure content was understandable. This meant using plain English, keeping text and sentences short.
SEPA’s brand colouring was used which has been tested for accessibility. In the creatives WCAG standards were checked and for those with impaired vision the colour palette and text have been tested. 
SEPA will continue to review its approach and consider if any reasonable adjustments which are required are included but not limited to additional training and development. This could be for example; considering whether a more flexible structure and approach is difficult for some colleagues

Include any further evidence gathering and external engagement that is required to demonstrate that you are giving ‘due regard’ to the equality duty of eliminating discrimination, promoting equality of opportunity, and fostering good relations.
•    Colleague feedback (internal)
•    Brand Agency (external)
•    Colleague engagement survey (internal)
•    benchmarking of other behaviour framework (external)
•    CLT and board feedback (internal)
•    HR feedback (internal)
 

Option 1: No major change

Your assessment demonstrates that the policy or practice is robust. The evidence shows no potential for:

•    less favourable treatment of particular groups, indirect discrimination, victimisation, harassment, and that you have taken all opportunities to advance equality of opportunity and foster good relations; nor 
•    restriction of Convention rights or freedoms.

The policy or practice builds in reasonable adjustments where these may be needed. In reaching this conclusion, you should document the reasons why and the evidence used to support your decision.

The framework has been developed following cross organisational engagement over a number of months to ensure that it can be used by all colleagues including managers and HR as key stakeholders.
External feedback has also been sought through third party contractors to ensure it aligns with work already developed and/or underway e.g. our values, senior leadership management.

The EqHRIA is a living document and should be reviewed and updated to ensure you have captured the changes that have been made because of the implementation of your policy or practice. Set a realistic goal for you to check back in with your assessment, to see if things are going the way you expected.

(01/12/2025)

22/11/2024

Yes