Systematic preventive work against discrimination (SFAD)

Content: 

• Organisation
• Collaboration in SFAD work
• Key points in ongoing SFAD work

Organisation

Here, faculties/equivalent refer to activities within the university that are at an equivalent organisational level to the faculties. This can correspond to the level of administrative heads within the central administration or other activities that are organisationally placed directly under the vice-chancellor.

Here, departments/equivalent refer to activities within the university that are at an equivalent organisational level to the departments, such as faculty-wide educational organisations (e.g., the medical programme or engineering programmes). This can also correspond to sections within the central administration or divisions within another activity.

Collaboration in SFAD work

In the work with SFAD, collaboration means that the university should conduct the work in such a way that employee organisations, employees, and students have insight into and can contribute to the work.

Unlike collaboration in work environment management, it is the employee organisations that you should collaborate with from the employer's perspective, not the safety representatives.

Key points in ongoing SFAD work

The work can be organised in different ways, but it is good to coordinate the work in a group where the department management/equivalent, employee organisations, employees, and students are represented. If the department has no educational activities, employee and student representatives are not needed in the group.

Seek assistance from the faculty's SFAD coordinator in planning, follow-up, and where needed otherwise.

During a twelve-month period, each department/equivalent and faculty/equivalent should:

• Assess whether SFAD work needs to be done from both the employer and education provider perspectives.
• Gather the functions that need to participate at the beginning of the calendar year and plan the layout of the four steps:
  • When and how should the investigations be conducted?
  • Can analysis and investigation be done simultaneously?
  • When is each step coordinated with employee organisations, employees, and students?
  • Who makes decisions about measures?
  • How are identified risks and measures communicated to employee organisations, employees, and students?
• Implement reasonable measures to address identified risks.
• Follow up to ensure that the measures have been implemented and have had the desired effect.
• If the measures have not been sufficient – is more analysis needed or can new measures be implemented?

Content: 

• In four steps within a twelve-month period
• Documentation of the SFAD work
• Step 1: Investigation methods and support materials for preventive work against discrimination
• Step 2: Analyse causes of identified risks and obstacles
• Step 3: Implement measures
• Reasonable measures against the risk of discrimination
• Step 4: Follow-up of the SFAD work
• Annual salary survey

In four steps within a twelve-month period

The SFAD work is carried out continuously in four steps within a twelve-month period. It is preventive, promotional, and ongoing work aimed at eliminating risks of discrimination and enabling equal rights and opportunities for our employees and students.

Documentation of the SFAD work

The documentation is intended to serve as support in the work. You should be able to follow the work and see what has been done and what remains to be done.

Documentation should be done continuously throughout the year and during the course of the work, and all four steps should be documented. Do not forget to document how you have collaborated with employee organisations or, where applicable, employees and students.

To document the ongoing work, templates have been developed: Support Document SFAD, Employer and Support Document SFAD, Education Provider. Links to the templates can be found in the right-hand column "Support Document SFAD". This documentation also forms part of the follow-up of the SFAD work. Read more under the heading Step 4: Follow-up of the SFAD work further down the page.

Step 1: Investigation methods and support materials for preventive work against discrimination

The first step in the SFAD work is to investigate risks of discrimination, reprisals, or if there are other obstacles to equal rights and opportunities for employees and students. There are several ways to investigate this. Here, as a manager, you can read more about how you can investigate risks of discrimination.

Keep in mind that you may need to conduct several investigations to identify risks and obstacles to the extent required; for example, it is not sufficient to only investigate whether experiences of discrimination exist.

Coordinate the work with, for example, the routines for systematic work environment management (SAM).

Investigation through group discussions

One way to investigate risks and simultaneously analyse their causes is to discuss the five areas from the employer and education provider perspectives in a group. This way, you can jointly come up with suggestions for appropriate measures.

Feel free to use the discrimination game to facilitate discussions. You can also investigate certain areas through discussions in management groups, at department meetings, or similar staff meetings.

The discrimination game – one way to investigate in a group can be to play the discrimination game and use the risk assessment template that comes with the game. The discrimination game is available at your faculty and can be ordered from MediaTryck (media-tryck [at] service [dot] lu [dot] se) at cost price. The game is available in both Swedish and English.

Investigation of risks of discrimination through group discussions. Guiding support materials are available in the right-hand column, one material for management groups and one for discussions in work groups at department meetings or similar staff meetings.

Investigation through individual conversations

Issues related to the risk of harassment and sexual harassment can sometimes be easiest to investigate in individual conversations, such as care conversations or development conversations with employees. It can also be good to have informal conversations in everyday life with individual employees or students when, as a manager or teacher, you pick up signals that something is not right.

Remember, if you find out that someone feels subjected to harassment or sexual harassment, you are obliged to investigate the incidents.

Read more about how to do this on the pages for harassment and bullying.

Tips on how to prevent harassment and bullying can be found in the Swedish Work Environment Authority's guidance on the regulations for social and organisational work environment (link to this is in the right-hand column).

Investigation through reported incidents of discrimination

Reported incidents of discrimination can also form part of the investigation of risks. Consider the incidents you have had within your organisation and how you can reduce the risk of something similar happening again.

When you receive a report of perceived discrimination, go through the four steps (investigate, analyse, take action, and follow up) with the reported incident as a starting point. Document the work so that you can account for it in the annual follow-up.

Investigation through survey tools

Parts of the investigation step can be done with a survey. A survey is often not a sufficient investigation method to identify risks of discrimination, and remember that you get answers based on the questions you ask. It is more difficult to ask follow-up questions, and you may not get all the information you need to analyse the causes of the identified risk.

Feel free to contact the SFAD team for advice.

Read more about the SFAD team and what local support is available in your organisation.

In the Template for OSA Survey (Swedish / English) in Sunet, there is a page with several survey questions to investigate risks of discrimination. Feel free to use these in connection with investigating risks within the organisational and social work environment.

Investigate risks of discrimination during a safety inspection

Every year, safety inspections are carried out in all organisations, and in connection with this, you can take the opportunity to investigate the risk of inadequate accessibility in premises. The IA system can be used as support in connection with physical safety inspections. The questions below are also included in the checklist for safety inspections in the IA system. Contact the occupational health engineer at the Occupational Health Service if you want to use the IA system as a tool when conducting safety inspections.

Examples of questions:

• Is it possible for people with different types of disabilities to access and pass through the main entrance?
• Are the areas where visitors stay accessible (entrance to the reception, cloakroom, toilets, other areas)?
• Are the toilets and staff areas adapted for people with disabilities?
• Are the premises and environment designed so that they do not cause discomfort for people with allergies or other sensitivities?
• Are the premises designed so that people with disabilities can take shelter in the event of a fire or other emergencies?
• Are signs, symbols, and texts in the premises designed to be accessible?
• Are stairs, doors, large glass surfaces, and other important functions such as doorbells and door openers contrast-marked?
• Is there access to hearing technology in meeting and conference rooms?

The university has decided that a social safety inspection (Dnr STYR 2023/1421) should be carried out at least once a year in all organisations that conduct teaching. The university has developed Guidance for Conducting Social Safety Inspections at Lund University, which should be used when conducting social safety inspections. The material contains several questions related to the five areas from the education provider perspective.

Read more about physical safety inspections and access protocols and support materials. Read more about social safety inspections and access the guidance. Download Support Document SFAD, Education Provider on the Forms and Templates page. Guidance on working for an accessible organisation is available from the Swedish Agency for Participation (see link in the right-hand column).

Step 2: Analyse Causes of Identified Risks and Obstacles

The second step in the SFAD work is to analyse the risks and obstacles to discrimination that you have identified through your investigations. Consider why the situation is as it is and try to draw some conclusions about which measures are most effective and reasonable to take.

When analysing risks and obstacles, it is important to have an open attitude and good cooperation with the representatives involved. An analysis based on traditional notions of, for example, gender, age, or religion can reinforce existing norms and prejudices. This can, in turn, lead to risks and obstacles not being detected.

A risk identified in one area can, when analysing the cause, point to other situations where a similar risk may arise. For example, if there is a risk of sexual harassment at the Christmas party, the same risk may also exist at other times, such as during staff days with overnight stays and on business trips.

Examples of questions to ask during the analysis:

• Why is the situation as it is?
• Do we have enough knowledge about risks and obstacles, or do we need more information?
• Do we need to gain more knowledge to understand what is behind the risks and obstacles we have discovered?
• Could there be similar risks in other situations?
• Are there any patterns?
• What are the causes of the identified risks and obstacles?
• To address the root cause or mechanisms behind risks and obstacles, we need to have an open approach and avoid drawing conclusions too quickly. It can be beneficial to involve several people who can view the situation from different perspectives.
• Are the risks and obstacles related to one or more grounds of discrimination?
• Do we have knowledge of all seven grounds of discrimination?
• Are we aware of common risks and obstacles that often lead to people being discriminated against?
• Do we need more knowledge?
• What can we do to eliminate risks and obstacles?
• It is not always easy to know which measures will effectively address risks and obstacles. Do we have enough knowledge to know which measures are effective?

Step 3: Implement Measures

Taking measures to eliminate risks of discrimination is to work preventively against discrimination, and through this, Lund University promotes equal conditions for our employees and students. We also work towards a good work environment.

Based on the risks and obstacles you have identified through the investigation and analysis steps, measures should be determined. The measures you decide on depend on the nature and extent of the risks and obstacles as well as the needs at the workplace.

As an employer and education provider, the university is obliged to take the measures that can reasonably be required. What is reasonable can vary from case to case – it depends on the needs that exist. The assessment should be made considering the conditions, resources, and other possible circumstances in the organisation. Read more about reasonable measures further down the page. The measures identified and found to be realistic and reasonable should be planned and implemented as soon as possible.

Keep in mind that the identified risks and obstacles should be addressed and that the measures taken should be significant for the organisation/concerned. On the other hand, if you do not identify any risks of discrimination, reprisals, or other obstacles to equal rights and opportunities, you do not need to take any measures.

Some risks may take a long time to address, and some measures may need to continue for several years. Since the work with the four steps within SFAD should be done within a twelve-month period, some measures may need to be divided. Measures that are expected to continue for several years need to be divided into sub-measures that can be followed up in the annual follow-up. Read more about the annual follow-up further down the page.

Examples of questions to ask when planning your measures

• What measures should be taken?
• Is one measure enough to address the risk/obstacle, or are several needed?
• Who is responsible for implementing the measures?
• The main responsibility always lies with the employer/education provider, i.e., with you as a manager. But who is appointed as responsible for practically implementing the measures?
• When should the measures be carried out?
• The measures should be planned and implemented as soon as possible.
• Are the measures possible to follow up?
• Can the results be followed up and evaluated in the long term so that we can ensure that the measures have the desired effect?

Examples of preventive measures

• The Discrimination Game is a tool that can be used both to investigate if there are risks and as a tool to discuss the issues in a somewhat more neutral way in a group. The game is available at your faculty office but can also be ordered (in Swedish and/or English) from Media-Tryck at media-tryck [at] service [dot] lu [dot] se, at cost price, if there are not enough copies at the faculty office.
• The university has developed a material that can be used by managers, HR, and others who work with groups. The material can be used to raise awareness about bullying, harassment, and sexual harassment. The material is available in the Competence Portal. Go to the material in English

Reasonable Measures Against Discrimination

What constitutes a reasonable measure can vary depending on the nature of the risk. Fundamentally, the principle of reasonableness means that the measure should be proportionate to the size of the organisation, budget, and the severity of the risk. Since Lund University is a large organisation with a substantial budget and many employees and students, the scope of reasonableness is greater than, for example, for an authority with 50 employees and a limited budget. There are limits to what can be considered reasonable even for Lund University, but it is not possible to provide definitive guidelines on where those limits lie.

Reasonable measures might include the university conducting teaching in premises with high or good accessibility, rather than building entirely new buildings or making extensive renovations.

A reasonable measure could be that teachers and others who lecture or speak to larger groups use the microphones available in the room. It could involve ensuring that everyone can participate in staff outings, including those who have difficulty moving, hearing, or seeing. It could also mean that the institution refrains from serving alcohol at festivities, as alcohol is known to increase the risk of bullying and harassment.

If you need support in discussing what constitutes reasonable measures, talk to the faculty's SFAD coordinator.

Step 4: Follow-up of the SFAD Work

By evaluating and following up the work, you can see if you have achieved what you intended and if identified obstacles and risks have been eliminated. Regardless of whether a measure has been effective or not, you can learn from the work and thereby see what needs to be done in the next cycle.

Follow-up of the Results of Measures

When a measure has been implemented, the result should be followed up. This is sometimes referred to as the "small loop," which means following up whether the measures have led to the desired result or if more needs to be done.

Examples of questions:

• Have we achieved what we wanted through the measures we have implemented?
• Have we eliminated the risks and obstacles we identified in the investigation and analysis?
• Have we implemented all the measures we decided on?
• Did the measures have the desired effect?
• Were there any measures that worked less well?
• Are other or additional measures needed?

Don't forget to document the follow-up of the results of the measures in Support Document SFAD, Employer and/or Support Document SFAD, Education Provider.

Annual Follow-up of SFAD Work at Lund University

The annual follow-up of the systematic preventive work against discrimination, SFAD, is conducted university-wide in the autumn with a deadline of 31 January each year. The follow-up is a review of how Lund University has worked over the past year to prevent discrimination and promote equal conditions. The follow-up aims to highlight how the SFAD work has functioned and whether and how the work needs to be improved or developed. The follow-up also ensures that Lund University meets the requirements for systematic and documented active measures as stipulated in Chapter 3 of the Discrimination Act (2008:567). The SFAD work is continuously documented in Support Document SFAD, Employer. If education is provided, the SFAD work is continuously documented in Support Document SFAD, Education Provider.

Links to templates are available in the right-hand column. The four steps are a circular process that is repeated to gradually and incrementally create improvements.

The follow-up at the faculty level must be completed by 31 January and is then summarised at the university-wide level in an equal conditions report published in April-May. The SFAD work takes place at all levels of the organisation and is followed up at the departmental/equivalent level, faculty/equivalent level, and university-wide level.

Departmental Follow-up Work

Each year, the department/equivalent follows up the previous year's SFAD work. The follow-up consists of a completed questionnaire and the department's SFAD documentation (Support Document SFAD, Employer and/or Support Document SFAD, Education Provider). The documentation is attached at the end of the questionnaire. Faculties plan when the departments' follow-ups should be conducted and send the questionnaire to the departments. The follow-up at the faculty level must be completed by 31 January, see the section below. The follow-up should be conducted in collaboration with employee organisations and/or students and employees. Read more about collaboration on the pages Systematic Preventive Work Against Discrimination (SFAD) at Lund University and Organisation of Preventive Work Against Discrimination for Equal Conditions.

If you have questions about the follow-up, contact the faculty's SFAD coordinator.

In Support Document SFAD, Employer and in Support Document SFAD, Education Provider, there is an opportunity to highlight other work within equal conditions that falls outside the SFAD work.

Faculty/equivalent Follow-up Work

Each year, the faculty/equivalent follows up the previous year's SFAD work. The follow-up consists of a completed questionnaire and the faculty's SFAD documentation (Support Document SFAD, Employer and/or Support Document SFAD, Education Provider) of the faculty-wide SFAD work. The documentation is attached at the end of the questionnaire. Also attach the report that summarises the departments' questionnaire responses. The follow-up should be conducted in collaboration with employee organisations and/or students and employees. Read more about collaboration on the pages Systematic Preventive Work Against Discrimination (SFAD) at Lund University and Organisation of Preventive Work Against Discrimination for Equal Conditions. Seek assistance from the faculty's SFAD coordinator in the follow-up work.

The follow-up is sent to the Council for Gender Equality and Equal Conditions by 31 January. If you have questions about the follow-up, contact the SFAD team at sfad-teamet [at] hr [dot] lu [dot] se.

In Support Document SFAD, Employer and in Support Document SFAD, Education Provider, there is an opportunity to highlight other work within equal conditions that falls outside the SFAD work.

Equal Conditions Report and Feedback from the Council for Gender Equality and Equal Conditions

When the Council for Gender Equality and Equal Conditions has received all faculties'/equivalents' SFAD follow-ups, an analysis and summary are made and presented in the annual Equal Conditions Report. The report provides recommendations for the continued work at the university-wide level.

The Council for Gender Equality and Equal Conditions provides feedback on the analysis of each faculty's SFAD follow-up to the faculty's SFAD coordinator.

Annual Salary Survey

According to the Discrimination Act, the university must annually conduct a salary survey of employees' wages to identify, address, and prevent unjustified pay differences between women and men. The university-wide survey and analysis work is carried out by the HR section in collaboration with employee organisations, in a joint survey group.

Read more on the HR web page about the salary survey.

There are support functions for the work on equal conditions and SFAD

All employees, contractors, doctoral students, and students at Lund University are responsible for contributing to a good work and study environment. At the same time, a greater responsibility lies with managers to work preventively so that no one is discriminated against.

The university has support functions that can help and support the work. In addition to those described below, several faculties also have other local support functions.

SFAD Coordinators are available at all faculties and equivalent units

At each faculty and equivalent unit, there is at least one employee who has the role of SFAD Coordinator. The SFAD Coordinator role is central to the SFAD work at the faculty/equivalent.

The SFAD Coordinator is well-versed in the four steps of the SFAD work, the routine for the annual follow-up of SFAD, and other important aspects of the faculty's equal conditions work. The SFAD Coordinator is part of the university-wide process group for equal conditions, where experiences, knowledge, and good examples are exchanged, and challenging questions are addressed.

The SFAD Coordinator can support both the employer perspective and the education provider perspective in the systematic preventive work against discrimination. In the right-hand column, there is a list of the university's SFAD Coordinators.

The SFAD Team is a University-wide Support

The SFAD Team is part of the central administration and supports SFAD Coordinators at faculties/equivalent in the ongoing SFAD and equal conditions work. The team participates in national and international networks in the field and collaborates with the Council for Gender Equality and Equal Conditions and the Vice-Rector responsible for courage and character.

The SFAD Team, together with the SFAD Coordinators, supports the units:

• In cases involving bullying and harassment,
• With methods for investigating the risk of discrimination,
• With documentation of the SFAD work,
• With follow-up of the SFAD work,
• With statistics for SFAD and equal conditions work,
• With oversight cases from or reports to the Equality Ombudsman.

Contact the SFAD Team via email: SFAD-teamet [at] hr [dot] lu [dot] se.

Raise Strategic Issues to the Council for Gender Equality and Equal Conditions

The Council for Gender Equality and Equal Conditions is a coordinating and advisory function at the university. Here, the rector's leadership and faculty leaderships work together to advance the work on equal conditions and gender equality at the university.

The council annually follows up on the equal conditions work, including the SFAD work, at the university and makes recommendations for initiatives or focus areas to the rector and the university board.

Read more about Equal Conditions and the Council for Gender Equality (Staff pages)