Wessely Review
Modernising the Mental Health Act: Increasing Choice Reducing Compulsion
Health & Social Care
Independent review of the Mental Health Act 1983 examining the rising rates of detention and the disproportionate number of people from BAME communities detained under the Act.
154recommendations
154Accepted
Government Response
White Paper published January 2021 accepting majority of recommendations. Mental Health Bill introduced to Parliament 2022. Royal Assent received 2025.
13 January 2021
Recommendations
Recommendation 1
A purpose and a set of principles should be included in the Act itself.
Recommendation 10
The Government and the CQC should consider ways to resource the likely increase in SOAD reviews, looking at how the model of SOADs can evolve.
Recommendation 100
Culturally-appropriate advocacy should be provided consistently for people of all ethnic backgrounds and communities, in particular for individuals of black African and Caribbean descent and heritage.
Recommendation 101
Safeguards should be created so that patients are able to continue religious or spiritual practices while detained in hospital. These should prevent the use of restrictive practices that limit a person's access to religious observance.
Recommendation 102
In line with the NHS Workforce Race Equality Standard programme, greater representation of people of black African and Caribbean heritage should be sought in all professions, in particular psychology and occupational therapy.
Recommendation 103
People of black African and Caribbean heritage should be supported to rise to senior levels of all mental health professions, especially psychiatry and psychiatric research, psychiatric nursing and management.
Recommendation 104
Behavioural interventions to combat implicit bias in decision-making should be piloted and evaluated.
Recommendation 105
Data and research on ethnicity and use of the MHA should be improved, with all decisions being recorded and reviewed consistently by organisations involved in the process – in particular criminal justice system organisations and Tribunals.
Recommendation 106
Funding should be made available to support research into i) the issues that lead to mental disorder in people of a wider range of ethnic minority communities, in particular African and Caribbean individuals; and ii) interventions which improve outcomes.
Recommendation 107
A call for research should be made into tailored early interventions for African and Caribbean children and young people, particularly those at risk of exclusion from school.
Recommendation 108
Legislation and guidance should make clear that the only test that applies in relation to those aged 16/17 to determine their ability to make decisions in relation to admission and treatment is that contained in the Mental Capacity Act.
Recommendation 109
In young people under 16, competence should be understood in this context as the functional test under the Mental Capacity Act, although without the presumption of capacity that applies in relation to those over 16.
Recommendation 11
The Government should consult upon: a. whether the MHA should provide that a person can consent in advance to confinement for medical treatment for mental disorder, or to empower an attorney or court appointed deputy to give consent on their behalf; and b. what safeguards would be required.
Recommendation 110
Young people aged 16 or 17 should not be admitted or treated on the basis of parental consent. The MCA (LPS) or MHA should be used as appropriate if they are unable to consent to their treatment.
Recommendation 111
Government should consult on the ability of parents to consent to admission and treatment for those under 16.
Recommendation 112
Every inpatient child or young person should have access to an IMHA who is trained to work with young people and their families.
Recommendation 113
Every inpatient child or young person should have a personalised care and treatment plan which records the views and wishes of the child or young person on each issue. Government should consider whether there should be a statutory duty for such a plan where the child or young person does not already have either a statutory care plan or a Care and Treatment plan under the MHA.
Recommendation 114
Initial Reviews should take place within five days of emergency admission (or three days if it is to adult facility) and at a minimum of four-to-six weekly intervals after that.
Recommendation 115
For children/young people placed in an adult unit, or out of area, the CQC should be notified within 24 hours. The CQC should record both the reasons for placement and its proposed length.
Recommendation 116
Government should consider making it a requirement that the parents and families of young people placed out of area are supported to maintain contact.
Recommendation 117
Section 17 of the Children Act 1989 should be amended to clarify that any child or young person admitted to a mental health facility is regarded as a 'child in need' so that parents can ask for services from their local authority.
Recommendation 118
The local authority for the area in which the child or young person ordinarily lives should be notified if a child or young person is placed out of area or in an adult ward or if admission lasts more than 28 days. For 'looked after children', paragraph 14.97 of the Code of Practice will continue to apply.
Recommendation 119
Where data is recorded it should be split into age groups.
Recommendation 12
Mental healthcare providers should be required to demonstrate that they are co-producing mental health services, including those used by patients under the MHA.
Recommendation 120
Health and social care commissioners should have a duty to collaborate to ensure provision of community based support and treatment for people with a learning disability, autism, or both to avoid admission into hospital and support a timely discharge back into the community.
Recommendation 121
Amend the MHA Code of Practice to clarify best practice when the MHA is used for people with autism, learning disability or both.
Recommendation 122
Care and Treatment Reviews should be given statutory force in the MHA.
Recommendation 123
The Mental Health Services Dataset should include specific data to monitor the number of detentions and circumstances surrounding that detention of people with autism, learning disabilities or both.
Recommendation 124
By 2023/24 investment in mental health services, health-based places of safety and ambulances should allow for the removal of police cells as a place of safety in the Act, and ensure that the majority of people detained under police powers should be conveyed to places of safety by ambulance. This is subject to satisfactory and safe alternative health based places of safety being in place.
Recommendation 125
Ambulance services should establish formal standards for responses to section 136 conveyances and all other mental health crisis calls and ambulance commissioners and ambulance trusts should improve the ambulance fleet, including commissioning bespoke mental health vehicles.
Recommendation 126
The responsibilities of NHS commissioners under section 140 of the Act must be discharged more consistently and more effectively, so that emergency beds are available.
Recommendation 127
NHS England should take over the commissioning of health services in police custody.
Recommendation 128
Equality issues, particularly police interactions with people from ethnic minority communities under the MHA, should be monitored and addressed. This should be under the proposed Organisational Competence Framework where possible.
Recommendation 129
Magistrates' courts should have the following powers, to bring them in line with Crown Courts: a. remand for assessment without conviction under section 35 of the Mental Health Act (MHA); b. remand for treatment under section 36 of the MHA; c. the power to commit a case to the Crown Court for consideration of a restriction order following an 'actus reus' finding; d. the power to hand down a supervision order following an 'actus reus' finding (where a person is not fit to enter a plea, but has been found to have committed the offence) under S1a of the Criminal Procedure (Insanity) Act.
Recommendation 13
Patients should be able to choose a new Nominated Person (NP) to replace the current Nearest Relative (NR) role under section 26 of the MHA.
Recommendation 130
Prison should never be used as 'a place of safety' for individuals who meet the criteria for detention under the Mental Health Act.
Recommendation 131
A new statutory, independent role should be created to manage transfers from prisons and immigration removal centres.
Recommendation 132
The time from referral for a first assessment to transfer should have a statutory time limit of 28 days. We suggest that this could be split into two new, sequential, statutory time limits of 14 days each: i) from the point of initial referral to the first psychiatric assessment; ii) from the first psychiatric assessment until the transfer takes place (this incorporates the time between the first and second psychiatric assessment and the time to transfer).
Recommendation 133
Decisions concerning leave and transfer of restricted patients should be categorised by the Ministry of Justice according risk and complexity. Straightforward and/or low risk decisions should be taken by the responsible clinician. The Ministry of Justice would have 14 days to override this decision.
Recommendation 134
The new statutory Care and Treatment Plan should include a plan for readmission and consider what factors should be taken into account concerning use of informal admission, section 2 and recall.
Recommendation 135
The powers of the Tribunal should be expanded so that they are able, when deciding not to grant an application for discharge, to direct leave or transfer.
Recommendation 136
The Government should legislate to give the Tribunal the power to discharge patients with conditions that restrict their freedom in the community, potentially with a new set of safeguards.
Recommendation 137
There should be an automatic referral for people on conditional discharge to the tribunal after 12 months and at regular intervals after that for patients who have not applied directly.
Recommendation 138
The Government should consider giving the Parole Board Tribunal status and combining hearings where appropriate. At the very least the Government should streamline processes so that hearings could be convened back to back.
Recommendation 139
There should be a common framework for assessment of risk across criminal courts, clinicians and the Justice Secretary. The assessment needs to be regularly reviewed (at least annually and before every Tribunal hearing). Every patient should have written in to the Care and Treatment Plan what their risk levels are.
Recommendation 14
A new Interim Nominated Person (INP) selection mechanism should be created for those who have not nominated anyone and do not have capacity to do so.
Recommendation 140
The new statutory, independent role for prison transfers should be extended to consider the least restrictive option for immigration detainees, including treatment in the community, informal admission and civil sections of the MHA.
Recommendation 141
The Department of Health and Social Care and the Ministry of Justice should work together to remove the gap in provision of information to victims of crimes committed by unrestricted patients, and to make sure victims are aware of their ability to make impact statements to the Tribunal in appropriate cases.
Recommendation 142
An agreed, accurate national baseline of use of the MHA should be established following a pilot programme to develop robust methodology.
Recommendation 143
A new official national dataset of AMHP activity should be created and integrated into the NHS Digital Mental Health Services Data Set.
Recommendation 144
Key data from the NHS Digital Mental Health Services Data Set should be published monthly as close to real time as possible.
Recommendation 145
Data on police use of detention powers under the MHA (sections 135 and 136) should be published on a quarterly basis as close to real time as possible and include new data on delays.
Recommendation 146
A national MHA data hub should be established to pull together and routinely analyse MHA data across NHS services, exploring possibilities for developing linkages across the various datasets, local authorities and policing.
Recommendation 147
The NHS, Home Office / policing and local authorities should work towards standardising ethnicity categories. This could be extended to all public sector reports including ethnicity.
Recommendation 148
NHS England should build on the work of the Mental Health Trust Global Digital Exemplars and other trusts to test, evaluate and roll-out a fully digitised, consistent approach to the MHA.
Recommendation 149
Work should be carried out to streamline activity undertaken between NHSE, NHSD, NHSI, CQC, Tribunals and providers, to include improved digitisation of notifications such as early discharge to avoid late cancellation of tribunal hearings.
Recommendation 15
Patients should have greater rights to choose to disclose confidential information to additional trusted friends and relatives, including through the NP nomination process or advance choice documents.
Recommendation 150
NHS Improvement and NHS England should fund the establishment of a national Quality Improvement (QI) programme relating specifically to the Mental Health Act.
Recommendation 151
The role of the CQC in monitoring the use of the MHA should be extended to cover all organisations that commission or provide services under the Act with due consideration given to the roles of other national bodies.
Recommendation 152
The factors that affect the timely availability of section 12-approved doctors and AMHPs should be reviewed and addressed.
Recommendation 153
The government should consider introducing a minimum waiting time standard for the commencement of an MHA assessment.
Recommendation 154
NHS England and NHS Improvement should consider the implications of the evidence linking staff morale and patient experience in the context of detained patients, and take action accordingly.
Recommendation 16
NPs should have the right to be consulted on care plans.
Recommendation 17
Patients under Part III of the MHA who are not currently eligible to have a NR should have limited eligibility for a NP/INP in relation to care planning.
Recommendation 18
The county court power to displace a NR should be replaced with a Mental Health Tribunal power to overrule or displace a NP, and only contested nominations should be heard in court.
Recommendation 19
NPs and INPs should be consulted about a renewal of a patient's detention, extension of a community treatment order, transfer from one hospital to another, and discharge, rather than simply notified.
Recommendation 2
There should be four new principles covering: choice and autonomy, least restriction, therapeutic benefit, and the person as an individual.
Recommendation 20
NPs should have a power to challenge treatment before the Mental Health Tribunal where the patient does not have capacity to do it themselves.
Recommendation 21
NPs should be given improved support, which could include courses provided by recovery colleges, support lines or online materials.
Recommendation 22
The statutory right to an Independent Mental Health Advocate (IMHA) should be extended so that it includes: a. all mental health inpatients, including informal patients; b. patients awaiting transfer from a prison or an immigration detention centre; c. people preparing their advance choice documents (ACDs) that refer to detention under the Mental Health Act.
Recommendation 23
IMHA services should be 'opt out' for all who have a statutory right to it and the CQC should monitor access.
Recommendation 24
The statutory definition of IMHA advocacy should be amended to cover advocacy around care planning and advance choice.
Recommendation 25
Further consultation should be undertaken on the training of advocates and quality standards, balancing the requirement for better quality services overall with the need for tailored interventions for specific groups.
Recommendation 26
Commissioning by local authorities should be strengthened, so that: a. guidelines make it clear that IMHAs are best placed to provide support in cases where there is an overlap with Care Act / MCA advocacy; b. services are commissioned on the basis of existing quality standards; c. providers are required to provide quarterly reports to their commissioners about issues and trends, incorporating input from trust staff, families/carers and clients; d. the requirement for IMHAs to be available to meet the needs of different groups, particularly ethnic minority communities, is strengthened, in light of the Public Sector Equality Duty.
Recommendation 27
Section 132 of the MHA should be amended to require managers of hospitals to provide information on making complaints to patients and their nominated person.
Recommendation 28
Staff dealing with complaints should have an understanding of the MHA so they are aware of the particular impact of detention.
Recommendation 29
Information going to hospital Boards should be separated between complaints made by patients detained under the MHA and complaints made by informal patients.
Recommendation 3
MHA regulations and forms should be amended to require professionals to record how the principles have been taken into consideration, and to enable local auditing and monitoring and CQC to consider this as part of their monitoring and inspection role.
Recommendation 30
The Government and CQC should take steps to improve the systems that handle complaints from patients and their carers across providers, commissioners, police and local authorities to improve transparency and effectiveness across the system.
Recommendation 31
Local Safeguarding Adult Boards should ensure that safeguarding arrangements support organisations to discharge their safeguarding duties and ensure that there are effective processes in place to identify, investigate and take action on safeguarding issues
Recommendation 32
A formalised family liaison role should be developed to offer support to families of individuals who die unexpectedly in detention.
Recommendation 33
Families of those who have died should receive non-means-tested legal aid.
Recommendation 34
Guidance should make clear that a death under DoLS/LPS in a psychiatric setting should be considered to be a death in state detention for purposes of triggering the duty for an investigation by a coroner and an inquest with a jury should be held.
Recommendation 35
There should be more accessible and responsive mental health crisis services and community-based mental health services that respond to people's needs and keep them well.
Recommendation 36
Research should be carried out into service models and clinical/social interventions that affect rates of detention.
Recommendation 37
The Government should resource policy development looking into alternatives to detention, and prevention of crisis.
Recommendation 38
There needs to be a concerted, cross-organisation, drive to tackle the culture of risk aversion. This will need to include the Chief Coroner, CQC, NHSE, NHSI, ADASS, LGA, patients, carers and provider boards, to understand the cultural drivers behind their different conceptualisations of risk and how they can be harmonised.
Recommendation 39
People should be treated as an inpatient with consent wherever possible. In order to give the informal admission more prominence section 131 of the MHA should be moved so that it sits above sections 2 and 3 of the Act.
Recommendation 4
Shared decision-making between clinicians and patients should be used to develop care and treatment plans and all treatment decisions as far as is practicable.
Recommendation 40
A patient's capacity to consent to their admission must always be assessed and recorded, including on the application form.
Recommendation 41
In order to be detained under the MHA, the patient must be objecting to admission or treatment. Otherwise they should be admitted informally or (as set out further under 'Deprivation of Liberty: MCA or MHA?') be made subject to an authorisation under the framework provided for under the MCA.
Recommendation 42
Detention criteria concerning treatment and risk should be strengthened to require that: a. treatment is available which would benefit the patient, and not just serve public protection, which cannot be delivered without detention; and b. there is a substantial likelihood of significant harm to the health, safety or welfare of the person, or the safety of any other person without treatment.
Recommendation 43
Detention should require a comprehensive statutory Care and Treatment Plan (CTP) to be in place within 7 days and reviewed at 14 days. This should set out: a. the full range of treatment and support available to the patient from health and care organisations; b. any care which could be delivered without compulsory treatment; c. why the compulsory elements are needed; d. what is the least restrictive way in which the care could be delivered; e. any areas of unmet need (medical and social); f. planning for discharge (including a link to the Statutory Care Plan recommended in the Care Planning and Aftercare chapter); g. how specifically the current and past wishes of the patient (and family carers, where appropriate) have informed the plan; h. any known cultural needs.
Recommendation 44
The Code of Practice should be amended so that, where a person has been subject to detention under section 3 within the last twelve months, an application for detention under section 2 can only be made where there has been a material change in the person's circumstances.
Recommendation 45
The Code of Practice should make it clear that section 3, rather than a section 2, should be used when a person has been already subject to section 2 within the last twelve months.
Recommendation 46
The detention stages and timelines should be reformed so that they are less restrictive through: a. introducing a requirement for a second clinical opinion at 14 days of a section 2 admission for assessment; b. extending the right of appeal for section 2 beyond the first 14 days; c. reducing the initial maximum detention period under section 3 so that there are three detention periods in the first year of 3 months, 3 months and 6 months; d. introducing a new time limit by which a bed must be found following an order for detention; e. requiring the responsible clinician and the AMHP to certify 10 days in advance of a Tribunal hearing for section 3 that the patient continues to meet the criteria for detention.
Recommendation 47
The tribunal should have the power, during an application for discharge, to grant leave from hospital and direct transfer to a different hospital, as well as a limited power to direct the provision of services in the community.
Recommendation 48
Where the tribunal believes that conditions of a patient's detention breaches the Human Rights Act 1998 they should bring this to the attention of the CQC (or HIW in Wales).
Recommendation 49
Tribunal should be given performance information by their local providers.
Recommendation 5
It should be harder for treatment refusals to be overridden, and any overrides should be recorded, justified and subject to scrutiny (see Annex on Treatment Choices).
Recommendation 50
A statutory power should be introduced for IMHAs and Nominated Persons to apply for discharge to the Tribunal on behalf of the patient.
Recommendation 51
A power should be introduced for SOADs and the CQC to refer a patient to the tribunal following a change in circumstances. This would expand, but not replace the current powers of the Health Secretary under section 67 of the Act.
Recommendation 52
There should be an automatic referral to the tribunal 4 months after the detention started, 12 months after the detention started, and annually after that.
Recommendation 53
For part III patients, automatic referrals should take place once every 12 months.
Recommendation 54
Only the MCA framework (DoLS, in future the LPS) should be used where a person lacks capacity to consent to their admission or treatment for mental disorder but it is clear that they are not objecting.
Recommendation 55
A patient could be held in hospital for a statutory period of up to 72 hours under MCA LPS amendments whilst it is determined whether the person is objecting.
Recommendation 56
Amendments to the MCA, the Codes of Practice, and relevant procedures before the Court of Protection and Tribunal should be made to clarify the position in relation to those in the community subject to both the MCA and the MHA. Dual authorisation under s.17 MHA and DoLS/LPS should not be required.
Recommendation 57
The criteria for CTOs should be revised in line with detention criteria.
Recommendation 58
The onus should be on the RC to demonstrate that a CTO is a reasonable and necessary requirement to maintain engagement with services and protect the safety of the patient and others. The evidence threshold should be raised for demonstrating that contact with services has previously declined, and that this led to significant decline in mental health.
Recommendation 59
Applications for a CTO should be made by the inpatient responsible clinician, with the community supervising clinician who will be responsible following discharge, and an AMHP.
Recommendation 6
Statutory advance choice documents (ACDs) should be created that enable people to make a range of choices and statements about their inpatient care and treatment. These should be piloted to identify the detail needed to inform/impact practice.
Recommendation 60
The Nominated Person/Interim Nominated Person will have the power to object to both applications and renewals of CTOs.
Recommendation 61
CTOs should have an initial period of 6 months, renewed at 6 months and then 12 months. Each renewal must involve two approved clinicians and an AMHP, unless the tribunal has recently reviewed the order.
Recommendation 62
CTOs should end after 24 months, though the RC should be able to make a new application.
Recommendation 63
As well as considering discharge, the Tribunal should, when refusing to discharge from the CTO, be able to order changes to the conditions of a CTO.
Recommendation 64
If no appeal is made to the Tribunal in each time period there will be an automatic referral.
Recommendation 65
The recall criteria should be updated and the process should be reformed to make it simpler.
Recommendation 66
Recall to alternative locations should be considered.
Recommendation 67
As set out in our chapter on Advocacy, IMHA services should be commissioned specifically for people on CTOs that requires providers to proactively approach the patient and offer their services.
Recommendation 68
If put in place, the effect of our recommendations on CTOs should be reviewed in no more than five years time, with a view to abolish CTOs if outcomes are not improved.
Recommendation 69
Wards should not use coercive behavioural systems and restrictions to achieve behavioural compliance from patients, but should develop, implement and monitor alternatives.
Recommendation 7
Decisions about medication should, wherever possible, be in line with the patient's choice and patients should have a right to challenge treatments that do not reflect that choice.
Recommendation 70
Providers should take urgent action to end unjustified use of 'blanket' restrictions applied to all patients.
Recommendation 71
There should be a Statutory Care Plan (SCP) for people in contact with CMHTs, inpatient care and/or social care services.
Recommendation 72
There should be a statutory duty for CCGs and Local Authorities to work together to deliver the SCPs.
Recommendation 73
Discharge planning should be improved, as part of the Care and Treatment Plan during detention, to ensure it is being considered from day one, and should be recorded and updated in the SCP post detention.
Recommendation 74
There should be better access to long-term support for everyone to keep them well and prevent admission.
Recommendation 75
There should be a clear statement in the new Code of Practice of the purpose and content of the SCP and section 117 aftercare.
Recommendation 76
There should be national guidance on how budgets and responsibilities should be shared to pay for section 117 aftercare.
Recommendation 77
The effectiveness of joint working arrangements should be subject to monitoring and review by the Care Quality Commission.
Recommendation 78
The managers of the hospital should continue to have the duty to scrutinise applications for detention, and should have a duty to scrutinise renewal documents.
Recommendation 79
The power of associate hospital managers to order discharge following a hearing should be removed.
Recommendation 8
Patients should be able to request a SOAD review from once their care and treatment plan has been finalised or 14 days after their admission, whichever is the sooner; and again, following any significant changes to treatment.
Recommendation 80
The Government and the CQC should consider developing a new independent 'Hospital Visitors' role, the main purpose of which is to monitor day-to-day life in the hospital and ensure that patients are treated with dignity and respect.
Recommendation 81
The managers of the hospital (those who actually manage the hospital) should continue to have the power to discharge a patient where fundamental errors have been made in either the admission or renewal paperwork.
Recommendation 82
The CQC should develop new criteria for monitoring the social environments of wards. These criteria should be the yardstick against which wards are registered and inspected and this should be reflected in ratings and enforcement decisions.
Recommendation 83
Patients should have a daily one-to-one session with permanent staff in line with NICE guidelines.
Recommendation 84
The physical environment of wards needs to be improved, through co-design and co-production with people of relevant lived experience, to maximise homeliness and therapeutic benefit and minimise institutionalisation.
Recommendation 85
The prompts and guidelines currently used for inspections in the assessment frameworks specific to mental health inpatient care should be reviewed with input from patients and their carers.
Recommendation 86
Risk assessments of issues such as infection control should be designed specifically for mental health inpatient care, and not lifted from other health settings. The unintended psychosocial effects must also be considered.
Recommendation 87
A review should be undertaken of the physical requirements for ward design for mental health units (e.g. the building notes, regulatory standards).
Recommendation 88
The backlog of maintenance and repairs needs to be addressed so that mental health facilities are brought up to standard.
Recommendation 89
The government and the NHS should commit in the forthcoming Spending Review to a major multi-year capital investment programme to modernise the NHS mental health estate.
Recommendation 9
Patients should be able to appeal treatment decisions at the Mental Health Tribunal following a SOAD review.
Recommendation 90
All existing dormitory accommodation should be updated without delay to allow patients the privacy of their own room.
Recommendation 91
The definition of single sex accommodation should be tightened up to ensure a genuinely single sex environment with separate access to any shared daytime space.
Recommendation 92
The CQC should review and update their inspection and monitoring of individual treatment and care to provide assurance that it meets the needs of people in different equality groups.
Recommendation 93
Reasonable adjustments should be made to enable people to participate fully in their care, including in relation to communication abilities.
Recommendation 94
A patient's physical health should be monitored, so that physical illness and conditions (e.g. diabetes and asthma) can be identified and treated.
Recommendation 95
The CQC should pay particular regard to obtaining patient (and carer) input from those who might find it difficult to articulate their views, including those in secure and out-of-area placements, those with learning disabilities or autism, children and young people.
Recommendation 96
Training should be developed for panel members in specialisms including children and young people, forensic, learning disability, autism, and older people.
Recommendation 97
Statistics should be collected on the protected characteristics of those applying for a Tribunal hearing, and their discharge rates.
Recommendation 98
An Organisational Competence Framework and Patient and Carer (Service User) Experience Tool should be implemented across health and care services. This should build upon ongoing work by NHS England to develop the Patient and Carer Race Equality Framework (PCREF).
Recommendation 99
Regulatory bodies such as the CQC should use their powers to support improvement in equality of access and outcomes. The EHRC should make use of their existing legal powers to ensure that organisations are fulfilling their Public Sector Equality Duty.