Diversity policy

Practical considerations when formulating a diversity policy

Articulate the benefits of diversity, including gender diversity, and the importance of being able to attract, retain and motivate employees from the widest possible pool of available talent.
Express the issuer’s commitment to diversity at all levels, including gender, age, cultural and educational background, and professional experience.
Assess the issuer’s diversity profile annually, including the gender balance of directors and senior management and their direct reports, and its progress on achieving its diversity objectives.
Ensure that the recruitment and selection practices at all levels (from the board downwards) are appropriately structured so that a diverse range of candidates is considered.
Focus on the development of a diverse pipeline - identify and implement programmes that will assist in building a broader pool of skilled and experienced employees for future senior management and board positions, and report on the outcome of such programmes (e.g. their impact on improving diverse representation at the more senior levels).

Diversity policy

Formulation of diversity policy

Issuers should integrate diversity into their strategies and operations. Efforts to promote greater diversity and inclusion should extend beyond the boardroom to senior management and the wider workforce. Issuers are encouraged to consider different aspects of diversity - including but not limited to gender, age, cultural and educational background, and professional experience.
The Listing Rules require issuers to have and disclose a diversity policy for the board and the workforce (including senior management). The diversity policy can be a standalone document, or it can form part of an issuer’s other firmwide / organizational document.
The board diversity policy should include measurable objectives (e.g. numerical targets and timelines) for the promotion of board gender diversity. The board is required to monitor the implementation of the policy and review it annually to ensure it remains fit for purpose. An annual review is required even if an issuer has achieved its current diversity objective.
Having a workforce diversity policy in place can assist issuers to set targets and objectives across the entire company, not just at the board level, and support the development of a diverse pipeline for succession. Since the demographics in a particular industry or country where an issuer operates may make it more challenging to formulate diversity targets at a workforce level, there is no requirement for issuers to set measurable objectives for workforce diversity.
Issuers are required to disclose the gender ratios of their (i) senior management and (ii) the workforce (excluding senior management). For the workforce gender ratio, issuers may disclose by categories of employees e.g. by level (middle management and rank and file), and/or by function (technical, administrative, or production).

Practical considerations when formulating a diversity policy