Submission from the Federation of Ethnic Communities' Councils of Australia attached as pdf.

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David Thodey AO


Independent Review of the APS

Email: https://contribute.apsreview.gov.au

FECCA submission regarding the Independent Review of the Australian Public
Service (the APS review)

The Federation of Ethnic Communities’ Councils of Australia (FECCA) is the national peak

body representing Australia’s culturally and linguistically diverse (CALD) communities and

their organisations. FECCA provides advocacy, develops policy and promotes issues on

behalf of its constituency to Government and the broader community. FECCA strives to ensure

that the needs and aspirations of Australians from diverse cultural and linguistic backgrounds

are given proper recognition in public policy.

FECCA supports multiculturalism, community harmony, social justice and the rejection of all

forms of discrimination and racism so as to build a productive and culturally rich Australian

society. FECCA’s policies are developed around the concepts of empowerment and inclusion

and are formulated with the common good of all Australians in mind.

FECCA would welcome the opportunity to expand on this submission as required. For

enquiries please contact FECCA CEO Dr Emma Campbell at emma@fecca.org.au or on (02)
6282 5755.


FECCA recommends:

 that the APS implement affirmative measures to increase the numbers of employees
of CALD background
 that the APS implement affirmative measures to increase the numbers of employees
of CALD background in senior executive positions, with a particular focus of women of
CALD background
 that the APS collect and publish data about workforce diversity including attraction,
retention and promotion of CALD Australians
 that the APS be more proactive in ensuring cultural and linguistic competence form
part of the inherent culture of the public service workplace and service delivery
 that citizenship requirements do not unfairly exclude otherwise suitable candidates
from employment within the APS by virtue of their immigration status

FECCA commends the APS for the establishment of the Secretaries’ Equality and Diversity

Council. The Council demonstrates commitment by the government to ensure diversity and

inclusion within the APS. FECCA commends the work of the Council in devising and

implementing diversity strategies including the Gender Equality Strategy, the Commonwealth

Aboriginal and Torres Strait Islander Employment Strategy and the APS Disability

Employment Strategy, however the absence of a strategy for CALD Australians is of great


FECCA recommends the creation and implementation of a diversity and inclusion strategy

that explicitly addresses CALD Australians, including affirmative measures to increase the

number of CALD employees across all levels of the APS.

Employee diversity in the APS

In the 2016 Census1, 26% of Australians were born overseas and 20% of Australians had at

least one overseas born parent. In the same year, 21% of Australians spoke a language other

than English at home and there were over 300 languages spoken in Australian homes.
The Australian Public Service should be a reflection of Australian society, to work for, and

represent the needs of, all Australians at a Commonwealth level. In order to ensure this, the

APS needs to be made up of individuals from a broad cross-section of Australian society and

in broadly proportionately representative numbers. This representation needs to be visible

across the APS as a whole, across individual departments, and across all employment levels

including the senior executive positions.
The most up-to-date publicly available data on employment demographics across the APS

indicate that ‘the proportion of APS employees who identified as being from a non-English

speaking background’2 is 14 percent3. This compares with the figure of 5.4% in 2012-13.
The definition used for the APS data collection in 2012-13 was that ‘people from non-English

speaking backgrounds are defined as those who were born overseas and arrived in Australia

after five years of age and whose first language was not English’4. It is not clear which

definition was used for the most recent data collection but if the same data collection

parameters were used, the reported cultural and linguistic diversity of the APS has increased

over the past decade.
Whilst ‘non-English speaking background’ is one way of capturing data on culturally and

linguistically diverse Australians, FECCA argues that utilising nationally consistent data

categories are more useful as they provide opportunity for comparing data sets more

accurately. Nationally consistent data categories similar to those used by the Australian

Bureau of Statistics would provide the APS with a clearer understanding of the representation

of CALD Australians in the workforce, and assist in devising targeted strategies to address

identified gaps.
FECCA notes that the level of reporting on CALD employees in the APS as part of the ‘State

of the Service Report’ has incrementally diminished in recent years. The 2012-13 report

provided specific data on ‘Employees from a non-English speaking background’, including

data on employee engagement and attraction, employee experience, satisfaction and

intention to leave. The 2016-17 State of the Service Report, under the ‘Representation of

diversity in the APS’ section, provided limited information on Indigenous Australians and




https://www.apsc.gov.au/sites/g/files/net4441/f/SOSR-2012-13-chapter-5.pdf, p108

people with disability only. FECCA notes with concern that there was no reference to CALD

employees in the APS.
FECCA recommends that the APS annually publish data regarding workforce diversity

including attraction, retention and promotion of CALD Australians. Data assists in identifying

gaps, risks and areas for improvement within the workforce and recruitment policies. Once

these have been identified, organisations can create strategies to address them. The

publication of data will also assist in ensuring that departments and agencies are accountable

for the objectives outlined in their Multicultural Access and Equity Plans, and that diversity and

inclusion strategies receive appropriate attention from senior leaders.
CALD leaders in the APS

CALD employees are under-represented in senior leadership positions across business,
academia, parliament and government departments and agencies in Australia. While

Australian society is incredibly culturally and linguistically diverse, the Australian Human

Rights Commission reports that of 124 heads of federal and state departments, less than 2%
of leaders have a non-European background.5

Evidence suggests that female employees from a CALD background face further difficulties in

attaining leadership positions in Australian organisations. A recent report by the Diversity

Council of Australia Capitalising on Culture and Gender in ASX leadership (2017)6 found that:
 The number of women ASX leaders from CALD backgrounds is very small: only 15 of
all 1,482 CEOs, 44 of all 2,327 senior executives, 188 of all 7,491 directors and 55 of
all 1,350 CFOs.
 The percentage of women ASX leaders from CALD backgrounds appears to have
plateaued between 2013 and 2015 – for almost all ASX groupings (i.e. ASX overall,
ASX 500, ASX 200, ASX 100) and all roles, whether a broad or narrow definition of
culturally diverse is used.
 Only 2.5% of all 7,491 ASX directors were women of CALD background, compared to
5.7% who were non-CALD women, 27.8% who were men of CALD background and
64.0% who were non-CALD men.
FECCA argues that Australian women of CALD background are affected not only by a range

of gendered employment and economic issues such as the gender pay gap, but also by

curtailed opportunities due of their cultural, linguistic and ethnic identities. These become more

evident in the more senior employment positions as shown by the ASX leadership data. Whilst

FECCA understands that the APS data on women of CALD backgrounds indicates that their

participation in mid-level positions is quite good, there is room for improvement with regards

senior executive positions, and in ensuring that they are well represented across all APS

departments and agencies.
The ability to successfully attract, develop and provide leadership pathways for CALD

Australians, should be reflected in diversity of employees at all levels of the APS. Current

figures suggest that the APS faces challenges in recruiting, retaining and promoting CALD

CALD Australians who reach leadership or senior positions have career pathways which are

facilitated by good mentoring and networking. It is important for people of CALD background

in more junior positions within the APS to see employees from similar backgrounds in

leadership roles so they know that career advancement and a pathway to the top is possible.
FECCA encourages the APS to implement a range of measures to ensure appropriate

Australian Human Rights Commission, ‘Leading for Change A blueprint for cultural diversity and inclusive leadership’, 2016,
available at


mentoring, networking, and career development pathways for people of CALD background,
with a particular focus on initiatives for CALD women.
FECCA strongly encourages the APS to become the leader in providing equitable access to

career promotion and professional development to employees from CALD backgrounds to

ensure that Australia’s diversity is reflected in the APS at all levels.
Cultural competence

There is an immense opportunity to encourage and improve cultural competence within

government departments and agencies. Cultural competence at the organisational level

involves developing systems, policies and processes that foster and encourage cultural and

linguistic diversity. Organisations with high levels of cultural competence are able to cultivate

diverse workforces, using cultural difference as a strength for more effective decision-making,
innovation and adaptability. They also understand the cultural profiles of the communities they

serve, and provide services that are representative of, and equitably accessed by, all


There are a number of ways that the APS can demonstrate commitment to cultural and

linguistic diversity and cultural competence across all departments and agencies, including:

 Prioritising cultural competence training as an integral part of workforce development
and training
 Allocating funding and resources towards cultural competence training for all staff,
including senior leadership
 Prioritising face-to-face or blended learning opportunities over online training programs
 Recognising cultural competence as a valued skill in the workplace and reflecting this
in recruitment policies and selection criteria

Cultural competence training is an integral part of fostering diverse and inclusive workforces

within the APS. FECCA research suggests that in fast paced and demanding workplaces,
cultural competence is often considered an issue of second importance amongst other

competing priorities. Additionally, leaders without lived experience often undervalue the need

to engage in cultural competence training. However FECCA believes that there is a great

opportunity for the APS to provide leadership in this area, ensuring cultural and linguistic

competence form part of the inherent culture of the public service workplace and service


Citizenship as a requirement for APS employment

FECCA understands that Australian citizenship is often required for employment within the

APS. This may be part of selection criteria depending on the department or agency, or may

arise from the need to obtain a security clearance, for which Australian citizen is compulsory.
For residents who are not yet eligible to apply for citizenship, or for those who are beginning

their application, the process of obtaining Australian citizenship can take a number of years.
This results in the exclusion of strong candidates who are otherwise suitable for APS roles, by

virtue of their immigration status. Recent proposals to lengthen the number of years of

residency before an individual is eligible to apply for citizenship would have impacted further

on the ability of otherwise suitable candidates to take up APS employment opportunities.

FECCA acknowledges that for certain roles within the APS, obtaining Australian citizenship or

undergoing a security clearance is a vital part of ensuring the security of the Commonwealth.
However, where APS roles do not require contact with sensitive information, FECCA

recommends that appropriate potential candidates should not be excluded from applying for

a vacancy on the basis that they do not have Australian citizenship. This is in the interest of

ensuring that ‘all eligible members of the community are given a reasonable opportunity to

apply to perform the duties’.7

FECCA recommends that the APS review the appropriateness of citizenship and security

clearance requirements for particular roles that may disadvantage those who are ineligible or

awaiting citizenship, thus restricting otherwise suitable candidates from gaining employment

within the APS.



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