If your latest social compliance audit, or your customer's code of conduct, includes a requirement to have a dedicated equity approach in recruitment, training, development and promotion processes, you could be forgiven for wondering what, precisely, you're supposed to show. It's a recent addition to social audit methodologies, so most sites have never been asked for it before, and most sites' first answer, the non-discrimination policy, isn't quite it. The gap between the two is what this piece attempts to explain.
This requirement is generally not raised as a standard non-compliance. Where a gap is found, most audit methodologies treat it as an aspirational requirement, a prompt to act, not a mark of failure. Further, and critically, the auditor is not expecting you to have solved inequity. Barriers of this kind can take years and outside expertise to shift, and audit methodologies recognise that. What the auditor is checking is whether you have an approach and a plan. A finding is raised in three situations: there is no approach at all; there is an approach on paper, but nothing that sets out what the site will actually do across recruitment, training, development and promotion; or parts of the workforce have been left out of it.
Equality treats everyone the same. Equity asks whether that's enough.
Equality means applying the same rules to everyone: the same job advert, the same training invitation, the same promotion criteria. Equity asks a further question, which is whether everyone can actually access those things on the same terms. Take a training course offered to every worker but run only on day shift, only in English. On paper it's equal. If your night shift is largely migrant workers, in practice it isn't.
This scrutiny falls most heavily on gender, and on workers facing compounded barriers, such as migrant women or those on temporary contracts. The goal is not a 50/50 headcount in every role, and no auditor is counting towards a quota. The real question is whether something about how work is organised puts the same job further out of reach for some workers than for others: how roles are paid, when shifts run, who hears about opportunities.
What "dedicated" means in evidence terms
"Dedicated" is doing real work in this requirement. Auditors aren't just checking that you avoid discrimination; they're looking for evidence that someone in your business has deliberately thought about fairness in hiring, training, development and promotion, and written down what they intend to do about it. There is no prescribed format. What matters is that the approach exists somewhere you can point to, that it covers all four processes, and that it says what you plan to do, not just what you believe. As the examples below show, that can be as light as a two-page procedure or as substantial as a programme built with outside experts; the bar scales with the business.
That's the floor. The ceiling, what separates a credible approach from a paper one, is whether anyone examines who is actually getting hired, trained and promoted, and acts when the pattern looks wrong. Outcome data isn't strictly what this requirement tests, but it's what protects you across the discrimination requirements proper, where findings are non-compliances. Here's what both look like at three very different sizes of business.
The small business: a 45-person garment finishing unit
Working: There's no HR department and no glossy strategy document. No auditor expects one. What the owner can show is a two-page equity procedure covering all four processes: every vacancy posted on the noticeboard before any word-of-mouth hiring; a simple skills matrix, updated quarterly, showing cross-training spread across men and women rather than concentrated in one group; and a recent supervisor role filled through an open internal process. Workers confirm they knew the role was available and how to apply. It's modest, but it's written down, it's deliberate, and it covers everyone.
Not working: Hiring runs through the production manager's personal network; three of the last five recruits are his relatives. Cross-training goes informally to "reliable" workers, which in practice means men on permanent contracts, while women on seasonal contracts have done the same single operation for years. Asked about an equity approach, the answer is "we treat everyone the same." Nobody here set out to discriminate, but there is no approach and no plan, which is precisely the first thing this requirement exists to catch, and the pattern in the training records is drifting towards a discrimination finding in its own right.
The medium business: a 600-person food processing plant
Working: An HR manager holds named responsibility for the equity approach, and it explicitly includes agency workers, the point where mid-size sites most often fail. There's a short action plan reviewed annually: recruitment agencies must follow the site's selection criteria and their shortlists are checked for skew; training runs across all shifts with interpretation in the site's three main languages; and the site tracks how many women and agency workers move into supervisory roles, treating it as a measure of whether advancement is genuinely open.
Not working: The same plant has an impressive, ISO-referenced equal opportunities policy signed by the managing director, but no plan of action sits beneath it, and agency workers are simply absent from it. Training happens on day shift only, in English, so the largely migrant night shift never attends. All 34 line leaders are directly employed local nationals, despite migrants making up 60% of production and nobody in HR has ever calculated that figure. This fails the requirement twice over: nothing setting out what will actually be done, and a whole worker demographic excluded from the approach. The paperwork would pass a desktop review. The equity approach stops at the boundary of the direct workforce.
The large business: a 1,500-person automotive components manufacturer
Working: Part of a multinational group, the site has equity governed, resourced and measured. Group policy cascades into a site-level action plan with a named HR business partner accountable for delivery, developed with input from a specialist NGO. Workforce data is broken down by gender, nationality, contract type and grade, and reviewed quarterly by site leadership, with minutes to prove it. When the data showed female operators applying for team leader roles at half the rate of men, the site built a mentoring scheme and now tracks the gap closing. This is well beyond what the requirement demands; it's also what makes the site resilient across every discrimination requirement.
Not working: The corporate machinery all exists: group policy, a D&I page on the careers site, annual e-learning with 98% completion. But there's no site-level plan for how any of it applies to recruitment, training, development or promotion here. The dashboard tracks only headline gender split, which looks healthy because women are well represented in operator grades; nobody breaks the data down by level, which would reveal women at 62% of operators and 4% of managers. And the salaried development programme that feeds the management pipeline is closed to hourly-paid staff, quietly excluding the entire shop floor, and with it most of the site's women and migrant workers, from advancement. Sophisticated documentation is masking the absence of both a plan and any scrutiny of outcomes.
The common thread
Notice what separates working from not working at every size: it is never the volume of documentation. The 45-person site with a two-page procedure passes; the 1,500-person site with a corporate D&I programme collects a finding. What the requirement asks for is genuinely achievable at any scale: a deliberate, written approach covering recruitment, training, development and promotion, that leaves nobody out and evidence that you're acting on it, even if the barriers themselves take time to shift.
If you manage a site, the practical questions to ask before your next audit are simple. Do we have an equity approach written down? Does it cover all four processes? Does it include everyone: agency workers, night shift, hourly paid? And who here actually knows who gets hired, trained and promoted, and when did we last check whether we liked the answer?
This is Part 1 of The Audit Trail, an Aseri series explaining complex audit requirements in practical terms. Aseri is a tech-powered social compliance audit, human rights due diligence and risk intelligence firm.
If any of this resonates with your business, we'd love to have a conversation, get in touch.