Equality, Diversity and Inclusion Policy

Our Equality, Diversity and Inclusion Policy

1. Introduction

1.1 This policy sets out our commitment and approach to Equality, Diversity and Inclusion.

2. About Funding Affordable Homes (FAH)

2.1 Funding Affordable Homes (FAH) is a social impact investment company that invests in the regulated affordable housing sector in the UK. We are a Luxembourg specialised investment fund that is authorised and regulated by the Commission de Surveillance du Secteur Financier. The majority of Investments in FAH are by institutional or professional investors wishing to invest in the UK affordable housing sector.

2.2 We define the term affordable as homes that are provided to meet identified needs and which are managed professionally under a regulatory framework. Our primary objective is to increase the supply of affordable housing across the UK. We intend to build a balanced portfolio of affordable housing to meet diverse needs and deliver a mix of income yield and capital appreciation for our shareholders. Since our inception in 2015 we have developed 768 homes across the UK.

2.3 FAH is governed by a Board of seven people. We have no direct employees, except for the Company Secretary of FAH Housing Association (FAHHA), one of our subsidiaries.

3. Funding Affordable Homes Housing Association (FAHAA)

3.1 Our subsidiary, FAHHA operates in the UK. It is a Registered Provider (RP) regulated by the Regulator of Social Housing (RSH). The RSH’s role is to promote a viable, efficient and well-governed social housing sector able to deliver homes that meet a range of needs. The RSH is sponsored through the UK Government’s Department for Levelling Up, Housing and Communities. Government grants for housing are administered via Homes England (HE). FAHHA is now responsible for the majority of our developments of new properties, including administering and accounting for affordable housing grants and overseeing the local management of our properties.

3.2 FAHHA is governed by a Board of five people and employs a Company Secretary/Legal Advisor. FAHHA does not manage homes directly unless there are exceptional circumstances where specific support is needed in any of the FAH investments. All landlord functions are undertaken by our partner RPs under legal agreements.

4. Our Key Partners

4.1 Both FAH and FAHHA are supported by external partners, including Edmond de Rothschild (EdR), whose staff provide Real Estate, Investment and other professional/advisory services, delivered by a team that includes staff previously employed by FAH who transferred to EdR. Examples of other key partners are Langham Hall, an international fund administrator that provides fund administration and depository services, and Fuchs Asset Management, part of the Fuchs Group whose services are as Alternative Investment Fund Manager (AIFM) to FAH.

4.2 Others with whom we have close working relationships include:

Big Society Capital, a substantial investor in FAH, whose mission is to improve the lives of people in the UK by connecting social investment to charities and local enterprises.
Joseph Rowntree Foundation, also an investor, is an independent organisation working to inspire social change through research, policy and practice.
The Good Economy, our social impact advisor

4.3 We procure other services from advisors such as law firms and external consultants.

5. Policy Statement

5.1 FAH is committed to practicing equality of opportunity, promoting diversity and having an inclusive approach. The term Equality, Diversity and Inclusion (EDI) covers:

Equality: Being fair and ensuring that individuals, or groups of individuals, are not treated less favourably because of their protected characteristics. The law defines protected characteristics as age, disability, gender reassignment or transgender status, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, ethnicity and national origin), religion or belief, sex and sexual orientation. We also recognise that people may be disadvantaged because of factors such as socio-economic status and vulnerabilities. With support from our Local Authority and RP partners we remove barriers and make reasonable adjustments to avoid disadvantage, so that people from all backgrounds can access homes and associated services delivered through funds we raise.
Diversity: Recognising that, though people have things in common with each other, they are also different in many ways. Diversity is what makes us different because of protected characteristics and other factors such as life experiences, cultural backgrounds and other non-visible differences.
Inclusion: Enabling everyone to feel included and where people pull together to create an environment of mutual respect. Inclusion is also where people can feel they belong and can participate in society because they are seen and valued for who they are.

5.2 EDI principles are at the core of our aim to maximise the affordability of our homes by focussing on developing homes for those who cannot afford to rent from the private rented sector or buy properties outright. Our strategic objective and plans are to work in geographical areas with prominent levels of housing need and have influence on lives.

5.3 EDI is fundamental to the way ‘we do things’ at FAH. We positively embrace and celebrate diversity and promote an inclusive culture in our role as a fundraising organisation. We acknowledge that everyone is different, and that people have unique needs and perspectives. Everyone brings their own contribution, experience, skills and knowledge to make FAH a successful organisation.

5.4 We believe that everyone has the right to live in a society free from discrimination, harassment, bullying and prejudice and be treated fairly and with respect. We will work to promote equality of opportunity and eliminate discrimination in line with the Equality Act 2010, the Regulatory Framework for Social Housing, and the Housing Ombudsman’s Complaints Code. Discrimination, victimisation, bullying or harassment is not tolerated.

6. EDI Policy Scope

6.1 Although we are not an employer or a provider of services directly to our ultimate beneficiaries (investors, tenants and homeowners), we have a responsibility to reflect EDI in the key functions that are under our control. Principally, these are:

a. Governance: We commit to:

Demonstrating an inclusive boardroom culture through board member behaviours and governance practices.
Making sure that all Board Members are fully aware of their responsibilities under this policy and for demonstrating leadership through inclusive decision-making where all voices are equally heard.
Setting FAH’s approach to practicing EDI through its work and identifying opportunities for EDI to further enhance the communities and our residents in the areas where we have investments.
Reflecting this policy in making judgements and business decisions, and where appropriate, seeking support from specialist advisors.
Regularly analysing our progress towards delivering this policy and identifying opportunities for continuous improvement.
Taking positive action to enhance EDI where possible, such as developing housing to
meet specific needs such as older age groups and vulnerable people.

b. Board diversity: We have control over three out of seven board positions as four are appointees of investor bodies. We commit to:

Removing, reducing and preventing obstacles to board membership, attracting diverse candidates for board membership when directly appointing board members.
Recruiting people who sign up to our values and principles of EDI and further contribute to inclusive approaches.
Making reasonable adjustments to meet the needs of disabled board applicants, new and existing members.
Considering positive action measures to reflect board diversity, such as considering opportunities to co-opt people with specialist diversity skills.

c. Employment. Although we are currently not an employer (except for the single case of the FAHHA Company Secretary), we commit to the following arrangements:

Removing, reducing and preventing obstacles to employment with FAH and attracting diverse candidates for selection.
Recruiting employees who sign up to our values and principles of EDI and reflect this policy in fulfilling their roles and responsibilities.
Ensuring that our human resource policies and practices are fair and inclusive and hearing the voice of diverse employees.
Make reasonable adjustments for disabled employees.
Reflecting EDI in employee performance management.

d. Partnerships and procurement. We commit to:

Collaborating with partners who demonstrate a commitment to the principles of EDI.
Require partners who work with us to inform us if they have faced legal or formal investigations relating to equality legislation by regulatory authorities such as the UK Equality and Human Rights Commission and the RSH.
Via FAHHA, requiring RP partners who deal with tenants and homeowners, either directly or via contractors, to ensure that they will meet the diverse needs of customers, such as overcoming communication barriers and supporting vulnerable people to access their services.
Via FAHHA, requiring RP partners to demonstrate that they seek and listen to the views of diverse tenants and homeowners and ensure that formal residents’ groups follow the principles of EDI and demonstrate an inclusive culture.
Via FAHHA, requiring relevant partners to inform us of complaints about discrimination from tenants and homeowners who live in our properties so that we can make informed decisions.

7. Roles and Responsibilities

7.1 This policy applies to everyone at FAH, including the Board and external partners with whom we work, including advisors, consultants and other agencies.

7.2 Everyone at FAH has a responsibility to implement and promote this policy. Individuals and groups have specific responsibilities as follows:

a. Board members should exercise leadership through policy and strategy approval, holding fund advisors to account for performance and demonstrating appropriate behaviour and conduct.

b. Teams and managers who advise FAH and other partners who deliver our day-to-day business and operations, are responsible for visible leadership, the overall implementation of the policy and strategy, reporting performance and setting standards for exemplar behaviour and conduct. They are required to exercise operational leadership, demonstrate strong application of the policy in their area of work and model appropriate behaviour and conduct. They must:

Ensure that their staff and others with whom they operate on FAH business are familiar with this policy.
Seek advice and guidance when necessary to implement the policy.
Help to highlight policies and practices that could lead to discrimination and unfairness and provide the necessary information to the FAH and FAHHA Boards as appropriate.
Take speedy and appropriate action to deal with complaints/incidents indicating actual or potential breach of this policy. Actions must be taken in line with established practices, policies and procedures relating to FAH.

8. Policy Review

8.1 This policy will be kept under review and be formally assessed at least once every three years.