Medr/2024/03: Supporting anti-racism in higher education: 2024/25 guidance and allocations

Introduction

1. This publication provides guidance to support anti-racism and race equality in higher education, and 2024/25 anti-racism funding allocations, match funding expectations, and monitoring requirements.

2. This guidance and funding has previously been referred to as ‘race equality’, but has been referred to as anti-racism funding since 2022 and the release of Welsh Government’s Anti-Racist Wales Action Plan.

3. This funding was originally provided in HEFCW circular W22/05HE: Consultation on funding to support race equality in higher education, to tackle anti-racism and support culture change in higher education, in line with race, access and success policy developments and the Anti-Racist Wales Action Plan. The initial publication included the conditions of match funding and the expectation that universities achieve a race equality charter award by 2024/25. All universities confirmed to HEFCW their intention to meet this commitment by the end of 2025.

4. This publication should be read together with HEFCW circular W23/06HE: Safe and inclusive higher education: supporting equality and diversity education.

5. HEFCW’s remit letter 2024-25 (paragraph 10), issued ahead of the transition into Medr, commended the work of Wales’s higher education sector in promoting equality of opportunity, including through its work towards the Anti-Racist Wales Action Plan.

6. Welsh Government is committed to an Anti-Racist Wales by 2030. At the time of writing, Welsh Government is refreshing its Anti-Racist Wales Action Plan to ensure progress at pace against overarching targets. There will be revised actions, including for the tertiary sector. We expect universities to take account of these actions as and when they are released.

Medr’s duties and responsibilities

7. Medr became operational on 1 August 2024 following the closure of the Higher Education Funding Council for Wales (HEFCW) on 31 July 2024.

8. Medr has a strategic duty to promote equality of opportunity in tertiary education. Paragraph 3.1 of the Tertiary Education and Research (Wales) Bill (as passed) notes:
“The Commission must promote –
a) the provision of support for students finishing courses of Welsh tertiary education who are members of under-represented groups to continue their tertiary education, find employment or start a business”.
b) increased participation in Welsh tertiary education by persons who are members of under-represented groups;
c) increased participation in the carrying out of research and innovation in Wales by persons who are members of under-represented groups;
d) retention of students who are members of under-represented groups to the end of courses of Welsh tertiary education;
e)reduction of any gaps in attainment in Welsh tertiary education between different groups of students where the differences arise from social, cultural, economic or organisational factors; and

9. The Act subsequently defines ‘under-represented groups’ to be:
a) “In relation to tertiary education, groups that are under-represented in Welsh tertiary education as a result of social, cultural, economic or organisational factors; and |
b) In relation to research and innovation, groups that are under-represented in the carrying out of research and innovation in Wales as a result of social, cultural, economic or organisational factors.”

10. Paragraphs 3.134 and 3.135 of the Tertiary Education and Research (Wales) Bill: Exploratory Memorandum requires Medr to “ensure that the ongoing registration conditions of each registered provider include conditions requiring the delivery of measurable outcomes relating to equality of opportunity.”  Medr will develop and consult on the registration process to supersede the current fee and access plan process operating between 2025/26 and 2026/27.

11. In addition to conditions relating to equality of opportunity, Medr will introduce a staff and student/learner well-being and safety related condition of registration. Paragraph 3.142 of the Tertiary Education and Research (Wales) Bill: Exploratory Memorandum notes: “The initial and ongoing conditions regarding support for and the promotion of student and staff welfare will introduce new regulatory requirements for providers which, it was envisaged, would encompass matters such as mental health, wellbeing and safety of learners and staff at the provider. The Commission will be required to set out and publish requirements which must be met by registered providers regarding their arrangements in respect to the initial and ongoing conditions. In the context of student and staff welfare, it is envisaged that ‘arrangements’ would include policies, procedures and support services for student and staff wellbeing and safety. ‘Wellbeing’ in this context is intended to mean emotional wellbeing and mental health. ‘Safety’ is intended to mean freedom from harms including harassment, misconduct, violence (including sexual violence), and hate crime.”

12. Medr will work with universities and colleges in 2024/25 and take account of the implications of working in a tertiary education context, sharing relevant practice as appropriate. HEFCW was a member of the Further Education Anti-Racist Wales Steering Group prior to its closure, to inform and support the transition to a tertiary education-focused organisation.

13. As Medr develops its policies, we will work with the tertiary education sector and partners to agree priorities, terminology and review data. We may issue supplementary guidance where appropriate as this work takes shape.

The purpose of anti-racism funding

14. This funding is to prevent inequality, tackle racism and support the embedding of anti-racist practice within universities and the wider tertiary education sector, support culture change, and contribute to delivering Welsh Government’s Anti-Racist Wales Action Plan.

15. The funding should contribute to universities achieving a race equality charter mark by July 2025, as outlined in the Anti-Racist Wales Action Plan.

16. While this funding is framed in terms of race and ethnicity, universities should take account of how tackling anti-racism will intersect with race, including, but not limited to identity-based harassment, violence and abuse, wellbeing and mental health, refugees and asylum seekers, and religion and belief.

2024/25 allocations and conditions of funding

17. In 2024/25, funding allocations:
i. are subject to universities committing to match fund allocations (as in 2022/23 and 2023/24);
ii. use HESA 2022/23 student data, which are based on the HESA standard registration population, reduced to a headcount (i.e. if a student has more than one enrolment, they are counted once);
iii. use student data which includes the whole student body: all modes, levels and domiciles;
iv. are based on verified 2022/23 HESA data which has been verified by the university;
v. as is our usual practice, Royal Welsh College of Music and Drama student data is included within University of South Wales data and allocation; and
vi. will be made as one payment in November 2024, subject to receipt of 2023/24 anti-racism monitoring reports.

18. Our expectations for the use of match funding are that:
i. the Medr allocation should not result in any decrease in universities’ existing resourcing of anti-racism developments, including their commitment to achieve a charter;
ii. universities commit additional resource to support anti-racism actions, over and above the Medr £1m total allocation;
iii. where any existing anti-racism activities or services are funded through fee and access plan or other sources, these activities and services may be increased by Medr or university match funding. Where this is the case, the university must make clear in all reporting and anti-racism monitoring how, and to what level, this funding has enhanced activities and services, and this may be subject to audit by us;
iv. the match funding and the Medr allocation leads to an increase in pace, and progress towards, tackling racism to embed anti-racist practices, improving race equality, and the achievement of a charter award; and
v. match funding or Medr funding can be used to meet the costs of relevant membership subscriptions, externally facilitated training or other external expertise.

19. 2024/25 allocations are as follows:

University	2024/25 HEFCW allocation (with £50K floor) £	2024/25 Sector matched funding (no floor) £	2024/25  Total £
University of South Wales	159,031	159,031	318,062
Aberystwyth University	53,590	53,590	107,179
Bangor University	72,491	72,491	144,981
Cardiff University	218,948	218,948	437,896
University of Wales Trinity Saint David	111,507	111,507	223,014
Swansea University	144,028	144,028	288,057
Cardiff Metropolitan University	90,446	90,446	180,891
Wrexham University	51,288	51,288	102,576
The Open University in Wales	98,671	98,671	197,343
Total	1,000,000	1,000,000	2,000,000

Resources and information

20. Universities UK has published two briefings on religion and belief which should inform race equality considerations: Tackling antisemitism: practical guidance for universities (June 2021) and Tackling islamophobia and anti-Muslim hatred: practical guidance for universities (December 2021). These briefings form part of Universities UK’s wider changing the culture series, which sets out evidence and recommendations in response to violence against women, harassment and hate crime affecting university students and staff.

21. In July 2022, the Higher Education Policy Institute (HEPI) published Gypsies, Romas and Travellers: The ethnic minorities most excluded from UK education. The report highlights challenges for Gypsy, Roma and Traveller learners, whilst highlighting best practice that exists across the UK, including the GTRSB^[1] into Higher Education Pledge introduced by Buckinghamshire New University in 2021 which commits signatories to:
i. naming a contact point for Gypsy, Traveller, Roma, Showmen and Boater students and prospective students;
ii. data monitoring of Gypsy, Traveller, Roma, Showmen and Boater students and staff numbers;
iii. building a supportive and welcoming culture for Gypsy, Traveller, Roma, Showmen and Boater students;
iv. outreach and engagement to local Gypsy, Traveller, Roma, Showmen and Boater communities; and
v. inclusion, celebration and commemoration of Gypsy, Traveller, Roma, Showmen and Boater cultures and communities.
^[1] GTRSB is used by Buckinghamshire New University as an acronym for Gypsy, Traveller, Roma, Showmen and Boaters. Medr aims to avoid the use of acronyms to describe people but we recognise their use in some resources included within this publication.

22. Three Welsh universities have been awarded University of Sanctuary status; the initiative recognises and celebrates universities that have undertaken work towards the values and principles of the City of Sanctuary Charter 2022-25, and who embody the City of Sanctuary network principles (through a ‘learn, embed, share’ structure).

23. All Further Education Colleges in Wales are affiliated organisations of the Black^[2] Leadership Group (BLG), which provides a range of training and development opportunities, as well as an Ethnic Representation Index (ERI) used by universities in England, Scotland and some specialist institutions.
^[2] ‘Black Leadership Group uses ‘Black’ as an inclusive definition for people from ethnically diverse backgrounds who share a lived experience of the effects of racism’.

24. In March 2024, Black Leadership Group launched the Higher Education Anti-Racism Toolkit (HEART). It has a ten-point plan to embed anti-racism in higher education systems (including strategy, pedagogy and the student and staff experience).

25. Medr and the Office for Students collaboratively fund Student Space. Student Space publishes dedicated wellbeing advice for, and by, higher education students, and has recently published ‘Life as a Black student’.

26. Medr is continuing to work with Advance HE to support two race equality seminars in 2024/25.

Deliverables and monitoring

27. Monitoring information and deliverables for 2024/25 period should build on 2022/23 anti-racism action plans submitted to HEFCW in October 2023, and updates submitted to us as part of 2023/24 monitoring. A monitoring template for submission has been provided in Annex A. 2024/25 deliverables and monitoring should include:
i. the university’s 2024/25 race equality action plan, including progress and deliverables to July 2025; and
ii. a funding statement to account for the Medr allocation and university match funding.

28. We are additionally seeking assurance that all universities are on track to provide a final submission to Advance HE for a race equality charter award by July 2025, as expected by the Anti-Racist Wales Action Plan. Universities must confirm by 1 November 2024 their timeline for charter mark submission and provide regular updates should delays arise. A template has been provided in Annex B.

29. We recognise that universities’ race equality charter action plans may prove satisfactory accounts for the majority of this funding and provide us with sufficient assurance on management and governance structures, annual milestones, pace, progress made and ambition. Where this is not the case, we will request additional information.

30. Should Welsh Government set new expectations on higher education, or the tertiary sector, during the funding period, we may ask for additional monitoring information.

Monitoring dates and returns for 2023/24 and 2024/25 funding and reporting

31. The 2023/24 monitoring submission date is Friday 18 October 2024. Information about deliverables can be found in HEFCW circular W23/20HE: Supporting anti-racism in higher education: 2023/24 guidance and allocations. Please return completed monitoring (Annex A of W23/20HE) to [email protected].

32. Universities should confirm their timeline for final submission to the Advance HE race equality charter award by Friday 1 November 2024. Please return completed form (Annex B) to [email protected].

33. The 2024/25 monitoring submission date is Friday 17 October 2025. Please return completed monitoring (Annex A) to [email protected] and [email protected].

Assessing the impact of our policies

34. We have carried out an impact assessment screening to help safeguard against discrimination and promote equality. We anticipate a positive impact on race, sex, disability, age, religion and belief. We have assessed the impacts on socio-economic characteristics and anticipate a positive impact on communities of interest^[3] and communities of place^[4].

^[3] Communities of interest are those who share an identity e.g. lone parents, carers; those who share one or more protected characteristic e.g. LGBTQ+, older people; groups of people who have shared an experience e.g. homelessness, the same local health/social care system or local service.
^[4] Communities of place are those who share a geographical location, (e.g. Wales Index of Multiple Deprivation (WIMD)).

35. We also considered the impact of this policy on the Welsh language, and Welsh language provision within the HE sector in Wales and potential impacts towards the goals set out in the Well-Being of Future Generations (Wales) Act 2015. Contact [email protected] for more information about impact assessments.

Further information and submissions

36. For further information and for submission of responses, please correspond with Orla Tarn ([email protected]).