Submission from the Federation of Ethnic Communities' Councils of Australia attached as pdf.
David Thodey AO
Independent Review of the APS
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 email@example.com or on (02)
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
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
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
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,
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.
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
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.