Guidance on Public Order and Firearms for Sikh Officers

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    Security Classification: NOT PROTECTIVELY MARKED

    Disclosable under FOIA 2000: Yes

    Author: CC Hughes Force / Organisation: Uniformed Operations

    Date Created: 5 January 2010 Telephone: 0114 252 3408

    Association of Chief Police Officers of England,

    Wales & Northern Ireland

    ACPO Guidance on Public Order & Firearmsduties for Turban wearing Sikh

    Police Officers

    Status: This Uniformed Operations Business Area Guidance hasbeen developed to provide clarity in relation to Sikh PoliceOfficers who wear turbans in respect of firearms andpublic order roles. It has been agreed at ACPO Cabinet.This document is not protectively marked and is fullydisclosable under the FOIA 2000. It has been registeredand audited in line with ACPO requirements and is subjectto copyright.

    ImplementationDate:

    Review Date:

    Copyright 2010. All rights reserved. Association of Chief Police Officers ofEngland,Wales and Northern Ireland. Registered number: 344583: 10

    Victoria Street, London. SW1H 0NN.

    March 2010

    March 2013

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    CONTENTS PAGE

    Section Pagenumber

    1. Preface 3

    2. Guidance, Advice and Procedures 4 11

    3. References 12

    ACPO WorkbookA

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    SECTION 1 - PREFACE

    1.1This ACPO guidance has been developed to provide clarity in relation to Sikh

    Police Officers who wear turbans in respect of firearms and public orderroles.

    1.2The guidance provides a foundation to encourage understanding anddialogue between managers and Sikh Police Officers and to support

    individuals who should be afforded choice around options for access tospecialist units.

    1.3Although no specially designed protective headwear for turban wearing Sikhofficers currently exists, this guidance will ensure that Sikh officers aretreated with dignity and respect - as well as giving a clear framework for

    decision making by managers.

    1.4This guidance also aims to articulate terms and conditions for recruitmentso that new and potential Sikh colleagues who wear a turban are aware ofpolice policies around this issue.

    1.5As part of the consultation process, a questionnaire was sent to over 400Sikh Police Officers in forces throughout England and Wales.1 The results of

    this survey will be used to inform any future work in this area.

    1.6This guidance has been developed by the ACPO Uniformed OperationsBusiness Area in consultation with the Home Office Scientific Development

    Branch, the Health and Safety Executive, UK Police Forces, partneragencies, staff associations, interested stakeholders and community

    representatives.

    1.7 Until a technical solution around developing specially designed protectiveheadwear for firearms and public order is explored in the future, thisguidance exists to balance the needs of the Police Service, in its role of

    protecting the public, with the needs and safety of individual Sikh PoliceOfficers who wear a turban.

    1Online Colleague Opinion Survey, January 2010

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    SECTION 2 - GUIDANCE, ADVICE AND PROCEDURES

    2.1 Introduction & Aim

    2.1.1 The aim of this guidance is to provide clear advice and support formanagers and Sikh Police Officers, including Special Constables, who wear

    turbans and may:

    Volunteer for public order duties

    Volunteer for firearms duties

    Be required to perform public order (Level 2) duties

    All of these roles require the wearing of specialist protective equipment,including protective headwear.

    2.1.2 The Police Service is committed to encouraging and welcoming allsections of society to join as police officers and for them to realise their fullpotential in finding career satisfaction in the many policing roles that are onoffer.

    2.1.3 As an employer, Police Forces are responsible for ensuring that all officersare treated fairly and with dignity and respect in the workplace.

    2.1.4 This document intends to promote operational effectiveness, whileminimising misunderstandings, discrimination or prejudice in line with UK legal

    and organisational requirements.

    2.1.5 Policing can present dangerous, demanding and rapidly changingcircumstances, particularly in public order and firearms situations. To meetthese requirements, there may be occasions where individuals need to beprotected with equipment in the interests of their own safety and that of theircolleagues. In these specific roles, there are increased risks that require ahigher level of personal protective equipment to be issued to officers for use inboth training and operational deployments.

    2.1.6 In general, religion is respected as a private matter. All Police Forceshave recognised that to harness and promote individual difference and removebarriers from joining the service then the practising of religious observance -

    such as the wearing of a turban by Sikh officers as part of their uniform - isappropriate, subject to operational effectiveness and health and safety

    requirements.

    2.2 Background

    2.2.1 Managers need to have an understanding and recognition of faith issuesto ensure that support can be given to individuals within the workplace, who inturn are expected to recognise the operational and business needs of theorganisation.

    2.2.2 The United Kingdom has the largest population of Sikhs outside of India,

    who have their origins in the Indian subcontinent. Sikhism was founded 500

    years ago in the Punjab region of north-west India, and the religion is veryclosely linked to the military history of the region. Sikh migration to the United

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    Kingdom began in the second half of the 19th Century and rose sharply in thepost-war period. The largest Sikh communities found outside India are in theUK, United States, Malaysia and Australia.

    2.2.3 Sikhs believe in one God and equality for all. The word Sikh meanspupil or discipline.

    2.2.4 Amritdharis Sikhs are those individuals who have been formally baptisedand are required to adhere to a code of conduct enjoined upon them at the

    time of baptism and keep the 5 Ks. However, Sikhs who are not baptised mayalso choose to wear any or all of the below 5 Ks, which are explained asfollows:

    Kesh uncut hair, observant Sikhs will not cut or trim their hair (Thissymbolises the uniqueness and identity of the faith)

    Kangha a small wooden comb usually worn in the hair (Worn forhygiene reasons)

    Kara - a steel bracelet worn on the wrist (A symbol of brotherhood and

    unity amongst Sikhs) Kachhahera knee length shorts (Traditionally worn at times of battle

    enabling ease of movement in combat)

    Kirpan a short sword (A symbol of spirituality and defence of those inneed)

    2.2.5 The balance for Police Forces, as employers, is to ensure Sikh officers areable to observe their faith, whilst balancing this against operationalrequirements, which is crucial in maintaining public confidence in the service,through whom officers are the most visible representatives.

    2.3 Legislation

    Any guidance must take account of employment legislation and below aredetailed the most relevant references:

    2.3.1 The Employment Equality (Religion & Belief) Regulations 2003

    This regulation provides the religion and belief elements of the EuropeanEmployment Framework Directive and implements them into UK legislation.These regulations came into force in 2003 and make it unlawful to discriminate

    against personnel on the grounds of religion or belief.

    The regulations apply to employment, including recruitment, terms andconditions of service, promotions, transfers, dismissals and vocational training.

    They also make it unlawful to directly or indirectly discriminate, harass orvictimise an individual in relation to the provision of references.

    Although forces have been practising policies that respect an individualsreligion or belief for some time, the new regulations make discrimination on thegrounds of religion or belief unlawful and give individuals a right to bringEmployment Tribunal claims for breaches.

    A headwear policy for personnel may inadvertently impact on Sikh officers who

    wear turbans in respect of public order or firearms duties. However, wherethere is a legitimate aim in relation to health and safety reasons, making a

    requirement for officers to wear protective headwear - this may prevent some

    Sikhs who wear a turban from taking part in this activity. This may be aproportionate means of achieving this legitimate aim.

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    However, care should be taken to ensure that force policies and practices donot have an unintentional adverse impact on those of a particular religion orbelief, and therefore, reasonable adjustments should be considered bymanagers.

    2.3.2 The Human Rights Act 1998 & Articles of the European Convention

    The European Convention of Human Rights (ECHR) was incorporated into UK

    domestic law with the enactment of the Human Rights Act 1998. Under ECHR,all public authorities have a positive obligation to ensure that the rights andfreedoms guaranteed by the European Convention are protected. The term

    public authority extends to all police forces. The Act commenced in 2000 andplaces a positive duty on public authorities to respect and uphold the HumanRights of all citizens. The main articles that can be considered are as follows:

    Article 9 Freedom of Thought, Conscience and Religion - This right has theobjective of ensuring the freedom of religion should be enjoyed in a democratic

    country and no discrimination or legal penalty should be held against anindividual who holds religious beliefs

    Article 14 Prohibition of Discrimination - Employees have the right to expectequality of treatment in respect of religion

    These articles are qualified rights, which define the right as requiring a balancebetween the rights of the individual and the wider community or state interest.Interference of a qualified right is only permissible when the action is inaccordance with the law, is necessary in a democratic society, and is in pursuit

    of a legitimate aim as specifically set out in the article, such as the protectionof health and safety.

    2.3.3Corporate Manslaughter & Corporate Homicide Act 2007

    This Act provides for a new offence called corporate manslaughter in England,Wales and Northern Ireland, and corporate homicide in Scotland. Undersection 1 of the Act, an organisation is guilty of an offence if the way in whichits activities are managed or organised:

    a) Causes a persons death; andb) Amounts to a gross breach of a relevant duty of care owed by the

    organisation to the deceased

    The organisation is guilty of an offence only if the way in which its activities are

    managed or organised by its senior management is a substantial element in thebreach referred to in the Act.

    2.3.4Health & Safety at Work Act 1974, Management of Health & Safety atWork Regulations 1992 and Personal Protective Equipment at Work Regulations1992

    These Acts, which police forces have a legal duty to comply with, ensuresemployers consider the health and safety of employees in the workplace, which

    is carried out via a risk assessment. Risk assessments will:

    a) Identify and assess the risks arising from work activities to workers and

    anyone else by workplace activities

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    b) Determine what measures are required to ensure safe workplace andsafe working practices to comply with legal duties

    This Act and regulations determine that if there is a risk of head injury, thenthis could be controlled by ensuring employees have suitable head protection

    while at work. The law sets out a hierarchy of control measures, such asremoving or controlling the risk of injury with the requirement to provideprotection for employees considered as a last resort.

    Employers who decide to protect their employees from head injury by usingonly head protection will need to show that it was not reasonably practicable toremove or control the risk by other means.

    2.4 Operational Framework

    2.4.1 Due to the heightened risks associated with public order and firearmsduties, both specialisms are subject to national standards defined by ACPO

    guidance and codes of practice. Both roles require specific training and frequentrefresher training in order for officers to maintain their accreditation foroperational deployments within their force areas as well as other forces as partof mutual aid requirements.

    2.4.2 For all forces, with variance for the PSNI, becoming an AuthorisedFirearms Officer is a voluntary role, whereas for Public Support Unit dutiesmany forces accept volunteers to fill these roles. Some forces, however,currently mandate that all, or all uniformed officers, are trained to nationalstandards.

    2.4.3 While the unique and challenging incidents that public order and firearms

    officers may find themselves deployed to are part of this policing activity, itshould always be borne in mind that the employer/employee relationship underUK legislation is still relevant and risk assessments are essential in mitigatingdangers to officers.

    2.4.4 Public order duties (level 1 & 2, see below) and firearms roles requirespecialist headwear to be worn in both training and operational environments.Protective headwear is worn to ensure the legitimate aim of ensuring individualand team safety.

    2.5 Public Order Capabilities & Standards

    2.5.1 Officers are currently trained to three levels of capability before being

    deployed to public order situations. Officers deployed outside their own force aspart of mutual aid arrangements must be trained to the level 1 or 2 standard.

    Level 1 Officers with the highest level of public order training who wearprotective helmets as part of their range of capabilities. These officers receiveregular refresher training and are trained in additional specialist tactics.

    Level 2 Officers are trained in the national common minimum standards ofpublic order tactics and are required to wear protective headwear.

    Level 3 Operational officers with a basic awareness of public order tactics,

    which are conducted in normal uniform.

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    2.5.2 Public Order Officers are also required to follow a code of dress for publicorder duties commensurate with the risk assessment for planned orspontaneous events and incidents.

    These codes of dress are for public order officers, which should not be confusedwith levels of training, and are as follows:

    Code 1 Full personal protective equipment, including helmet, fire protectivehood and wrist cuffs, body armour, shoulder, arm, thigh and shin pad

    protection, specialist boots, flameproof overall.

    Code 2 All the above personal protective equipment, but with normal dutyheadwear and typically normal duty jacket or fluorescent bib.

    Code 3 Normal duty uniform, worn by public order trained officers

    2.6 Options Considered

    2.6.1 Three options have been considered in respect of this issue:

    1. Wearing of a cloth turban in public order and firearms duties Following consultation with the Health and Safety Executive, it has beenestablished that a cloth turban does not offer the level of protectionrequired for either training or operational deployments and exposure tosuch risk would lead to breaches of legislation.

    2. Specially developed protective headw ear for Sikh officers who

    wear a turban although recommended for future exploration thisitem is not currently available.

    3. Wearing the existing issued protective helmet for publicorder/ firearms duties this is the supported option currentlyavailable

    2.6.2 There is a need for balancing the religious needs of the individual with therequirements for health and safety. Managers should be cognisant of the needto understand this issue, whilst ensuring that support is given to officers andthat, at no time, should the individual be expected to, or be faced with, therequirement to alter their observance of their faith.

    2.7 Guidance for Managers

    2.7.1 No requirement or agreement should be made for Sikh officers who weara turban to conduct firearms or public order (level 1 or 2) duties with any formof disclaimer around injury as this will expose the relevant force to a breach ofHealth & Safety legislation.

    2.7.2 Currently, there is no protective headwear for public order or firearmsthat is specifically designed for turban wearing Sikh officers.

    2.7.3 There is an option for Sikh officers who wear a turban to wear a patka(smaller head covering) under existing specialist headwear, however, this is a

    matter of choice for the individual and should not be directed by managers.

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    2.7.4 The following flowcharts demonstrate how these issues can beconsidered:

    2.7.5 Firearms Sikh police officer who wears a turban requests to be

    considered or applies for firearms duties

    2.7.6 Public Order Sikh Police Officer who wears a turban is mandated tocomplete Public Order duties (Level 2) in line with their force policy

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    2.7.7 Sikh Police Officer who wears a turban volunteers for Public Order duties

    (Level 1 & 2)

    2.8 Further Considerations

    2.11.1 Forces may wish to consider explaining the balance between individualreligious/faith requirements for Sikhs and operational policing requirements ininformation about the role of officers and special constables at the point ofrecruitment. This will ensure individuals are fully aware of the support andrequirements around this issue, as well as the avenues that are still available

    with forces for career progression and promotion.

    2.9 Questions and Answ ers

    Q: Will my unwillingness to remove my turban lead to discrimination bythe force?

    A: No. The decision for religion/faith to be respected within the workplace isprotected by the law and managers will ensure that positive action is taken toensure this is in place.

    Q: Do I need to remove my turban for operational duties?

    A: No. The wearing of the turban in normal uniform/plain clothes duties ispermitted and encouraged by Sikh officers if they so choose, the guidanceregarding Personal Protective Equipment is only of relevance in duties such as

    public order (Levels 1 & 2) and firearms duties where the risks associated withthe role are controlled by the wearing of a specialist helmet.

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    Q: Will wearing a turban have an effect upon my promotion andprogression w ith the Police Service?

    A: Although taking part in public order & firearms duties may give additionalexperience and skills to officers, there is no requirement for this to becompleted as part of any promotion examinations or interviews.

    Q: Will I be forced to remove my turban by managers?

    A: No. Under no circumstances will Sikh officers who wear turbans be asked toremove them for operational requirements, the choice will be made by theindividual, with no pressure to change by managers.

    Q: Would declaring my principles of religious/ faith observance aroundthe turban effect my chances of being employed as an officer with

    Police Forces?

    A: No. This would not form part of any interview process and the rights offairness are protected by legislation. The Police Service is an equalopportunities employer and positively promotes the inclusion of allcommunities. Success at interview would depend on achieving the competencesrequired.

    Q: Could my progress as a student officer be hindered by not takingpart in Level 2 public order training or deployments as mandated by

    the force, as my observance of my religion/ faith does not permit me toremove my turban?

    A: No. This guidance sets out clear procedures in respect of this and there is norequirement that such duties are completed as part of the student officerprogramme.

    Q: Could Sikh officer recruitment be affected by the guidancerecommendations?

    A: No. This guidance will give clarity to officers and managers on the issue toensure that legislative protection and operational requirements are clearlydefined and the reasons for these requirements are explained.

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    SECTION 3 References

    1. ACPO/NPIA Manual of Guidance on the Management, Command andDeployment of Armed Officers (2009)

    2. ACPO/NPIA Guidance on Public Order & Public Safety (2010)3. CHMIC Adapting to Protest Nurturing the British Model of Policing

    (2009)4. Head Protection for Sikhs wearing Turbans Guidance for Employers.

    Health and Safety Executive Guidance (1998)

    Consultation:

    Strategic Steering Group

    HH Judge (ret.) Sir Mota Singh, QCMr Ranjit Singh, OBE President of the Sikh Forum InternationalLord Tarsem King of West Bromwich

    Mr Parmjit Dhanda, MP for Gloucester

    Working Group

    British Sikh Police AssociationMetropolitan Police Staff AssociationWest Midlands Black and Asian Police Association

    With thanks to:

    Mr Rob Marris, MP for Wolverhampton South West and Chair of the All PartyParliamentary Group for UK Sikhs

    Agencies

    Prison ServiceMinistry of DefenceHealth and Safety ExecutiveSouth Yorkshire Fire and RescueHome Office Scientific Development BoardHuman Rights and Equalities CommissionYorkshire Ambulance ServiceAll UK Home Office and Non-Home Office Police Forces

    Sikh Police Officer Questionnaire

    The confidential and anonymous Online Colleague Opinion Survey (2010) wassent to over 400 Sikh Police Officers in forces across England and Wales. Forfurther details of this survey, please contact the Uniformed Operation BA staffofficer.

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    SECTION C - ACPO EQUALI TY IMPACT ASSESSMENT TEMPLATE(DIVERSITY AUDIT) AS AGREED WITH THE CRE

    C1. Identify all aims of the guidance/ advice

    C.1.1 Identify the aims and projected outcomes of the guidance/ advice:

    This ACPO guidance has been developed to provide clarity in relation to SikhPolice Officers who wear turbans in respect of firearms and public order roles.The guidance provides a foundation to encourage understanding and dialoguebetween managers and Sikh Police Officers and to support individuals who shouldbe afforded choice around options for access to specialist units.

    C.1.2 Which individuals and organisations are likely to have an interestin or likely to be affected by the proposal?

    Turban wearing Sikh Police Officers, all police forces in their personnel andrecruitment policies, police managers, staff associations (Federation,Metropolitan Police Sikh Association, British Sikh Police Association, West

    Midlands Black and Asian Police Association etc)

    C2. Consider the evidence

    C.2.1 What relevant quantitative data has been considered?

    Age

    Disability

    Gender

    Race

    Religion / Belief An online survey was sent to over 400 Sikh Police Officersthroughout England and Wales in order to gain their views

    as well as express issues and concerns around the wearingof the turban and likely routes of resolving the issues aroundaccess to specialist roles, career progression and retention.As of 27th January, 292 officers had responded to thissurvey. An evaluation of the results of the survey will takeplace and will be sent to the ACPO Equality, Diversity andHuman Rights BA to inform further work around Sikh issueswithin the Police Service.

    Sexual Orientation

    C.2.2 What relevant qualitative information has been considered?

    Age

    DisabilityGender

    Race

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    Religion / Belief As part of the project a strategic steering group and aworking group were established to gain the views andcounsel of those with a clear interest in the area of Sikhissues and the Turban.

    The strategic group included, Lord Tarsem King of West

    Bromwich, Mr Ranjit Singh President of the Sikh ForumInternational, HH Judge (ret.) Sir Mota Singh, QC, Mr

    Parmjit Dhanda, MP for Gloucester.

    The working group included representatives from theMetropolitan Police Sikh Association, the British Sikh Police

    Association and the West Midlands Black and Asian PoliceAssociation.

    Consultation was also made with the Health and SafetyExecutive, Human Rights and Equalities Commission, theMinistry of Defence, Fire Service, Ambulance Service, Prison

    Service, all UK Police Forces (Home Office and Non-HomeOffice) on legal, policy and support issues.

    Consultation with the Home Office Scientific DevelopmentBranch was made in respect of technical issues.

    Consultation and advice was sought from Mr Rob Marris, MP,who is chair of the All Party Parliamentary Group for UKSikhs.

    Sexual Orientation

    C.2.3 What gaps in data/ information were identified?

    Age

    Disability

    Gender

    Race

    Religion / Belief It was clear that the largest gap was a lack of guidance forforces/managers on this issue, which had resulted in severalemployment tribunals being pursued as well as poortreatment of Turban wearing Sikh officers due to lack ofunderstanding or processes.

    Sexual Orientation

    C.2.4 What consideration has been given to commissioning research?

    Age

    Disability

    Gender

    Race

    Religion / Belief Past research commissioned by the West Midlands Police and

    Metropolitan Police informed some of the current projectwork. The results of the Sikh officer survey will inform futureprojects by ACPO/NPIA.

    Sexual Orientation

    C3. Assess likely impact

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    C.3.1 From the analysis of data and information has any potential fordifferential/ adverse impact been identified?

    Age

    Disability

    Gender

    Race

    Religion / Belief Although there will still be cases where Turban wearing Sikhpolice officers will be prevented from Public Order andFirearms duties, this guidance fully explains the reasons forthis as well as giving practical support for both officer and

    manager. This guidance gives a proportionate response to amatter that is extremely pertinent to some officers andshould be respected in balancing individual needs andorganisational operational requirements.

    Sexual Orientation

    C.3.2 If yes explain any intentional impact:

    Age

    DisabilityGender

    Race

    Religion / Belief The guidance will ensure that all forces implement policieswhich are in line with the law as well as ensuring the safetyof officers and staff who may be required or volunteer forcertain specialist duties. Although not the intention of thepolicy to exclude any officer, it is clear that some officers willnot be able to perform such duties in line with this policy.

    Sexual Orientation

    C.3.3 If yes explain what impact was discovered which you feel is justifiable in order to achieve the overall proposal aims. Pleaseprovide examples:

    Age

    Disability

    Gender

    Race

    Religion / Belief The guidance is built on the legal requirements for

    organisations under the Health and Safety at Work Act 1974as well as specific guidance related to Sikh employees.Liabilities and risks to forces from non compliance with thislaw may bring prosecution as well as consideration underthe Corporate Manslaughter Act.In contrast the Human Rights Act gives many rights aroundfreedom of expression to the individual and an expectationthat these should be respected by forces.This Guidance intends to bring together the rights of the

    individual and the requirements of forces under the law totry and establish an equitable and fair way of dealing with a

    sensitive issue.

    Sexual Orientation

    C.3.4 Are there any other factors that might help to explain differential/ adverse impact?

    Age

    Disability

    Gender

    Race

    Religion / Belief N/A

    Sexual Orientation

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    C4. Consider alternatives

    C.4.1 Summarise what changes have been made to the proposal toremove or reduce the potential for differential/ adverse impact:

    Due to the current technical limitations to consider the design and issue of a

    bespoke helmet to cover a Turban, this Guidance intends to ensure thatprocedures are adopted around the current equipment available to forces.

    C.4.2 Summarise changes to the proposal to remove or reduce thepotential for differential/ adverse impact that were considered butnot implemented and explain why this was the case:

    Two considerations were made: firstly, that Turban wearing Sikh officer shouldonly have to wear a cloth turban for public order and firearms duties. This wasidentified as illegal by the Health and Safety Executive and would expose forcesto breaches under the Health and Safety at Work Act 1974 and the Corporate

    Manslaughter Act.Secondly, a specially designed helmet to cover the Turban was considered,

    however, this does not currently exist or is in development.

    C.4.3 If potential for differential/ adverse impact remains explain whyimplementation is justifiable in order to meet the wider proposal

    aims:

    The Guidance gives a proportionate response to the issue, but more importantlyensures that officers are treated with respect for their choice by managers and

    the limitations around equipment are explained, as well as the need forprotective equipment in the specialist roles of public order and firearms.Technological advances in the future may assist with a reflection upon thesituation.

    C5. Consult formally

    C.5.1 Has the proposal been subject to consultation? If no, pleasestate why not. If yes, state which individuals and organisationswere consulted and w hat form the consultation took:

    Age

    Disability

    Gender

    Race

    Religion / Belief Formal consultation with the project working group has

    taken place and all groups broadly support it.

    Sexual Orientation

    C.5.2 What was the outcome of the consultation?

    Age

    Disability

    Gender

    Race

    Religion / Belief Support for the proposed guidance

    Sexual Orientation

    C.5.3 Has the proposal been reviewed and/ or amended in light ofthe outcomes of consultation?

    Yes, some amendments were made to the document, but nothing to the overall

    options or decisions that underpin the document

    C.5.4 Have the resu lts of the consultation been fed back to theconsultees?

    Yes, all consultees are in possession of the document, prior to CC cabinet.

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    C6. Decide whether to adopt the proposal

    C.6.1 Provide a statement outlining the find ings o f the impactassessment process. If the proposal has been identified ashaving a possibility to adversely impact upon diversecommunities, the statement should include justification for

    the implementation:This guidance will not adversely impact upon the Sikh community, but will giveclarification around the matter to both current and future officers around thewearing of the Turban for certain specialist duties.

    C7. Make Monitoring Arrangements

    C.7.1 What consideration has been given to piloting the proposal?

    No consideration has been given to piloting this proposal.

    C.7.2 What monitoring will be implemented at a national level by

    the proposal owning agency and/ or other national agency?Monitoring will take place with leading Sikh Police staff associations.

    C.7.3 I s this proposal intended to be implemented by local agenciesthat have a statutory duty to impact assess policies? If so, whatmonitoring requirements are you placing on that agency?

    N/A

    C8. Publish Assessment Resu lts

    C.8.1 What form will the publication of the impact assessment take?

    It is recommended that for publication on the ACPO website, the impactassessment be attached to the completed document as the first appendix. On theACPO Intranet, the whole workbook will be attached to assist in the preparation

    of local audits.