Review criteria
How we use these criteria
When a Pledge signatory shares evidence, Sentient reviews it against the five criteria below. The criteria cover every protected characteristic in the Equality Act 2010: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. We look at outcomes across protected characteristics, including both sexes, in both directions, and for both the person raising a concern and the person it concerns.
A review records what evidence was supplied and whether it meets each criterion as written. It is a review of the documents supplied, on the date shown. It is not an audit, a site visit or legal advice, and we do not test whether the evidence is accurate beyond what the documents themselves show.
To hold the mark "Pledge member, evidence reviewed", an organisation must meet criteria 1, 4 and 5, and supply evidence for criteria 2 and 3 (or explain in writing why it cannot yet do so, with a date for when it will).
No public copy, by Sentient or by a signatory, may suggest that criteria 2 or 3 are "met". A dated plan whose date passes without evidence counts as "Not supplied" at the next review.
Criterion 1: Reasonable steps on harassment (Equality Act 2010 s40A)
From 30 October 2026, employers must take all reasonable steps to prevent sexual harassment of their staff (s40A); the duty protects staff of any sex. We also look at steps to prevent harassment related to any protected characteristic (s26).
Evidence that counts
• A current harassment policy, dated, that covers harassment related to every protected characteristic, applies to all staff, and covers harassment by third parties such as customers and clients.
• A written risk assessment, with actions, owners and review dates.
• Training records in aggregate (for example, percentage of staff and managers trained in the last 12 months).
• A description of reporting routes, including at least one route outside the line manager.
• Aggregate numbers of reports received and how they were resolved, split by type of harassment and by protected characteristic (including the sex of the person reporting and the person reported), subject to Criterion 5.
What this criterion does NOT confirm
• That the steps taken are "all reasonable steps" in law. Only a tribunal can decide that.
• That harassment does not happen, or that any individual complaint was handled correctly.
• That policies are followed in practice.
Criterion 2: Outcomes after leave and after a complaint
We look at what happens to people after family leave (maternity, paternity, adoption, shared parental and parental leave) and after they raise a complaint or grievance.
Evidence that counts
• Aggregate return and 12-month retention rates after each type of leave, across protected characteristics, including both sexes.
• Aggregate progression and pay-change outcomes in the 12 months after return, across protected characteristics, including both sexes.
• Aggregate outcomes for people who raised a complaint or grievance (still employed after 12 months, moved role, left), across protected characteristics, including both sexes.
• A short note on any difference found and what the organisation is doing about it.
What this criterion does NOT confirm
• That any individual was treated fairly or lawfully.
• That differences have a particular cause.
• That the data supplied is complete. We review what is supplied.
Criterion 3: Adjustments and requests
We look at how the organisation handles requests such as flexible working, reasonable adjustments for disabled staff (Equality Act 2010 ss20–22) and requests linked to caring responsibilities, religion or belief, or pregnancy and maternity.
Evidence that counts
• A request log summary in aggregate: numbers received, agreed, agreed with changes and refused, by type of request and across protected characteristics, including both sexes. Reasonable adjustment requests (ss20–22) are reported separately.
• Average time to decision.
• The written process, including how refusals are explained and how people can appeal.
What this criterion does NOT confirm
• That any individual decision was right or lawful.
• That the organisation meets its legal duties on flexible working or adjustments.
Criterion 4: Measurable objectives
Evidence that counts
• At least two written objectives, each with a baseline figure, a target, a date and a named role responsible (a role, not a person's name, on any public summary).
• Objectives that can be measured across protected characteristics, including both sexes, or that say which group they focus on and why the data supports that focus.
• For annual review: the latest figure for each objective against its baseline, and what changed.
What this criterion does NOT confirm
• That the objectives are sufficient for any legal duty, including the public sector equality duty or any publishing duty.
• That the targets will be met.
Criterion 5: Data rules (must be met for every submission)
• Aggregate only. Totals, counts and percentages. No names, staff numbers, case details or anything that identifies a person.
• No cell under 10. Any figure based on fewer than 10 people must be suppressed (shown as "<10") or combined with another group. This includes figures that could be worked out by subtraction from other figures.
• The organisation stays controller of its data. Sentient acts as processor under a written processor agreement (UK GDPR Art 28) before any data is shared.
• No special-category data about individuals. Data on protected characteristics such as disability, race, religion or belief and sexual orientation is shared only as aggregate figures that meet the cell rule above.
• Where a split would produce a figure based on fewer than 10 people, the organisation combines categories or leaves that split out. Two characteristics are never cross-tabulated unless every figure is based on 10 or more people. Harassment figures are never split in a way that could identify the person reporting or the person reported.
Evidence that counts
• Submissions that follow these rules throughout. We return any submission that does not, and do not keep it.
What this criterion does NOT confirm
• That the organisation's wider data protection practice meets UK GDPR.
What a review result looks like
For each criterion: "Met", "Evidence supplied, not yet met" or "Not supplied", with the date of review. Results are private to the organisation. Only the status ("Pledged" or "Pledge member, evidence reviewed") and the review date appear on the register, with consent.
Changes to these criteria
We date every version. A review is always against the version in force on the review date. We give signatories at least 60 days' notice of any change.
Every use of the mark carries this wording, exactly:
"This shows the organisation has signed the Sentient Equality Pledge and supplied evidence that Sentient reviewed against its published criteria on [date]. It is a membership, not an award or quality mark, and it does not confirm that the organisation meets any law."
[date] is a per-entry field: the date of that organisation's last review.