KPMG Gibraltar pre-summit DEI seminar - Sarah Gardner speech

08 July 2024Speech by Sarah Gardner

This speech was delivered by deputy chief executive Sarah Gardner at the KPMG Gibraltar pre-summit DEI #WeAllWantToPlay seminar on 26 June 2024.

Please note: This is the speech as drafted and may slightly differ from the delivered version.

Thank you for that introduction and thank you everyone for being here. I had the privilege of being able to speak at this event last year and I’m really pleased that the organisers have committed to putting the issue of gender diversity at the heart of this event for another year at, what I’m sure will be a very interesting and successful conference.

Making the case for a better approach across the gambling sector when it comes to Diversity, Equity and Inclusion is not something that is really for the regulator to do. As I observed last year, there is nothing in the Gambling Commission’s statutory duties which obliges us to focus on this issue per se and we therefore don’t impose regulatory requirements in relation to it, in the way that some other regulators do. However, we remain committed to it and keen to engage in the debate with the industry and other stakeholders. So today I want to make the case for why diversity is important and why everyone should be taking it seriously in their organisations, not as a regulatory thing; but as the right thing for well-run business to do. I’ll put my money where my mouth is a bit here and share our approach at the Gambling Commission and our own D&I Strategy. Not because we think we have all the answers or because we think we have nailed this now but because we’re on a journey as I know many of you are and sharing learning in this space strikes me as a good thing to do. I’ll talk about our own journey towards better representation in our Leadership and Management cadre and our next steps in this area as well.

But first, let’s start with looking at the big picture. Why is the subject of diversity important and why in the gambling sector?

Happily, I don’t get asked the question about why on earth the regulator might think about this as often as maybe I did a few years ago. The understanding that this is the right thing to do in and of itself is becoming more widespread. Back then though, I think there was from some quarters, a view that this was something the regulator shouldn’t have a view on and shouldn’t be talking about. As if the culture and leadership of a company had nothing to do with what else the company does.

As I say, this view is now changing and not before time. But that doesn’t mean that we shouldn’t restate the case whenever we can. There is plenty of research out there showing that diversity is important to good governance, leading to better decision making, and better outcomes – something of course the Commission is very keen on. And it’s clear that diversity of opinion and diversity of thought helps to prevent a closed culture and closed minds. This can only be a good thing.

And as I’ve said before: this is absolutely consistent with our statutory remit. How our licensees are run, how they make decisions and ensure those are good decisions all matter to our remit. As you will have heard from Andrew, our CEO, myself and others, the Gambling Commission wants compliance at the earliest opportunity from our licensees. We are much more likely to achieve that with businesses which are well run, making sound decisions. And the research on this is clear, as I’m sure those in the room who are better versed in it will tell you, that diverse organisations make better decisions which take account of a fuller range of factors. When you look at it in these terms I don’t think there is a debate as to whether diversity is important. It’s clear. Diversity and a diverse leadership is a critical factor in good governance.

And for our part, we clearly need to make sure we have that same inbuilt diversity as well. Regulation is all about balance, all about sourcing and thinking about evidence from a range of perspectives. How can we understand the range of perspectives if we ourselves don’t have proper representation across our work and leadership too.

Being at the heart of what we do, I think this is therefore why this agenda has been a strong internal focus for us at the Commission and I’m happy to say when you look at our leadership and our pay gap report, that focus appears to be delivering real results.

We now have an Executive team that is majority women: 7 out of 11 in fact. And I’m pleased to say that the last round of recruitment which DCMS undertook to recruit to the Gambling Commission Board, our Commissioners, brought further diversity there as well. We now have a gender balanced Board which is a great position to be in and I think is a really important ingredient in our approach to considering the big issues. And on our pay gap, in our latest published Gender Pay Gap report that covers 2022 to 2023, it shows that we are making good progress on this front as well. The report shows the mean, or average, pay gap is down to 0.1 percent in men’s favour whilst the median, or middle, gender pay gap is now 1.2 percent in women’s favour for the first time.

This progress has plenty of benefits of course. Not just to our decision making and diversity of thought but also to our culture and how attractive we are as a place to come and work. There is, of course, still more to do though. For example, next year we are looking to voluntarily publish an ethnicity pay gap report alongside the gender report. A focal point for our efforts though is the Commission’s Diversity and Inclusion Strategy.

We introduced our first Diversity and Inclusion Strategy last Summer and I’m pleased to say it’s having an impact as we go about embedding it. Our vision is to create meaningful change, allowing all individuals to feel empowered to be themselves. This in turn will help to continue making the Gambling Commission a great place to work.

The Strategy itself was crafted with the input and insight of our colleagues and based on that insight, it aims to deliver three outcomes by 2026:

• maximise opportunities to attract, develop, support and retain diverse representation at all job levels throughout our workforce
• develop an inclusive culture, where colleagues can be themselves and create a sense of belonging
• grow our reputation as an inclusive employer that values the rich spectrum of diversity.

We’ll do this through a number of ways, through embedding our commitments, how we engage with colleagues and how we equip them with the tools to take this further in their teams and work as well. It has already led to a step change in our communication work, how we look at our busy calendar of engagement opportunities and how we plan for the long term. It’s also really important to state that our work to progress the Strategy is data driven, which in turn will help us to make informed decisions, setting realistic targets to manage expectations. And that data will come from our work to measure success through:

• employee diversity data to measure progress in recruiting, retaining, and developing underrepresented groups. We'll set targets and compare data with external sources to ensure we reflect the communities we serve
• including diversity and inclusion indicators in our staff surveys, we can establish a baseline measurement and gain insight into our employees' experiences. This will help us determine whether we are making progress in promoting diversity and inclusion
• and we’re aiming to obtain and uphold accreditations in diversity and inclusion standards, and regularly report on our progress. Additionally, we aim to enhance our Disability Confident Employer status by achieving the Disability Confident standard.

Year one is of course about making sure we have the basics right and already in the first year so far we have:

• initiated and Integrated diversity and inclusion into our policies, practices, and processes. Leaders must show visible support and communicate expected actions and behaviours
• embedded diversity and inclusion into the Gambling Commission’s wider strategy and increased focus on an inclusive culture
• started to grow mutual and Commission wide understanding that everyone is responsible for, and achieves, diversity and inclusion goals that create meaningful change
• and we’ll sustain and promote diversity and inclusion through our brand to align external perceptions with internal reality. This includes evaluating all decisions through a diversity and inclusion lens.

A concrete example of what I’m talking about here is perhaps how we use the data we gather to drive forward further progress. For example, by completing a deep dive into the ‘Great Place to Work’ survey data, and analysing the results across different demographics, we were able to identify that LGBTQ+ colleagues were not feeling the same level of belonging as other groups of colleagues. This led us to focus on supporting the growth of the Pride Network group, as well as holding a series of events for LGBT History month. Subsequent internal pulse survey scores have shown a dramatic improvement in this area. Besides this we’ve also:

• successfully trialled and then implemented an anonymous recruitment process, that removed personal identifiable information from the application and interview short listing process
• we’ve supported and fostered the development of colleague network groups across the Commission, which has already resulted in the launch of 3 new groups in less than a year, the Parents and Carers Network, the Pride Network I mentioned and the Neurodiversity Network
• and we continue to hold inclusivity events throughout the year, such as celebrating Black History Month, Mental Health Awareness Week and National Inclusion Week. The aim of which being to raise awareness, inform colleagues and develop the cultural competence of our organisation.

So I’m pleased to say that we’re making strides across these areas. And I’m confident in saying that as we have embedded the monitoring of progress in the Strategy. Starting from the top, with oversight from Board and Executive level, we also have a Diversity and Inclusion Steering Group, which I chair, overseeing the day-to-day delivery and an Operating Group made up of colleagues from the Commission working to share ideas, raise challenges, and support implementation.

Ultimately, every leader at the Commission is expected to embrace diversity and make inclusive decisions as set out in our Leadership Expectation standards. By doing so, both collectively and personally, we believe we can successfully achieve our diversity and inclusion outcomes.

So hopefully I’ve demonstrated our commitment to the wider work in promoting diversity and inclusion and of course this all applies to advancing and cultivating women’s leadership as well.

I already talked a bit about our pay gap earlier and how women’s leadership is being made a reality at the Commission but what I didn’t say earlier is that the Gambling Commission employs more women than men across the board. We have been able to claim that at various points over the years but it’s fair to say that where women were employed in the organisation and their seniority was not always as good a story to tell. Like many organisations, women have traditionally dominated some of our functions and grades and have been almost absent in others. There have been times when I have been the only woman on our Executive team, for example. But all of that is changing so now we see that from the lowest paid, through middle grades through to senior leadership level: at every pay ‘quartile’ we have more women than men. So it’s now, I would say, the norm to find women actively leading and shaping Commission’s work at every level. And I am very proud of that.

I must give some credit here for some of that impetus for change coming through the support of people outside of the Commission. It does help to be able to talk to others and see what others are doing in this area, as we try to move our own dial in this space. As I’ve already said, it’s great to see the commitment of Micky, KPMG for organising today again and all of you for taking part. I’d also like to highlight the great work being done to get the UK/European initiative related to the Global Gaming Women group off the ground, and for engaging with some of us at the Commission in those efforts. Among others, I’d like to thank Brigid Simmonds, Anna Davies, Grainne Hurst, Vicki Reed and Bethan Lloyd who have helped get that group up and running. It’s important for all the reasons we’ve already discussed that women have a forum where they can discuss these issues and importantly how they can – working with allies - be supported to advocate and lead the change required in their workplaces. Colleagues at the Commission and I will continue to support the group’s efforts and I hope to see many of you doing so as well.

So what next? Well I think it’s important we keep talking and we keep sharing what works on these issues. We need to continue supporting events like this, breakouts at wider sector events need our support and we all need to be advocating for our Executive and Board to focus on these issues where we haven’t got it already. For those organisations and operators who haven’t looked at implementing their own Diversity and Inclusion Strategies, I’d urge you to do so.

For our part, we will continue to push these issues. Externally by continuing to speak but also behind the scenes, like working to avoid agendas or panels where only men’s voices are heard. Internally too, we will continue to use the tools I’ve already discussed and our staff surveys to track how we’re progressing. We’re incredibly proud to have been accredited a ‘Great Place to Work’ two years in a row. Part of that accreditation this year recognised the Commission for how it has embraced new working practices and embedded an inclusive culture, prioritising wellbeing and teamwork. Something I’m very proud of and something I think is so important in the modern working world.

And of course, we’ll continue progressing against our Diversity and Inclusion Strategy.

The work of course is never done. I feel like that is a mantra many women can relate to. But actually as I stand here today I am reassured that we are making progress. Your efforts are making a difference. And I am sure, that the work to embed, strengthen and promote women’s leadership in gambling doesn’t just have a positive impact for the women who work in the sector. It has a positive impact across the board: in innovative thinking, in building successful companies and in making gambling safer, fairer and crime free.

Thank you again for listening and I look forward to the rest of the discussions.

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Last updated: 8 July 2024

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