Equality Impact Assessments - Triple Lock

Summary

The request sought Equality Impact Assessments and meeting minutes regarding the decision to end the triple lock and introduce the Manx Pension Guarantee. The Treasury disclosed three documents, including an Equality Impact Screening Assessment and a Full Equality Impact Assessment, confirming that the policy change was assessed for its impact on protected groups.

Key Facts

• The Treasury completed an Equality Impact Screening Assessment (EISA) on 10/01/2024.
• A Full Equality Impact Assessment (EQIA) was required and completed for the policy change.
• The policy involves changing away from UK policy and removing the increase at the higher of average earnings.
• The assessment was conducted by Sarah De-Yoxall from the Social Security Division.
• The outcome of the FOI request was that all requested information was sent.

Data Disclosed

• 2025/26 Annual Budget
• 10/01/2024
• 2025-02-11
• 2025-03-19
• 9 pages
• 3 documents

Original Request

Please provide copies of the equality impact assessment, the equality impact screening document or any other assessment of the equality impact, or compliance with the equality act, in relation to the decision to end the triple lock / introduce the Manx Pension Guarantee/Manx Double Lock.  Please also provide copies of the meeting minutes where this policy to end the triple lock / introduce the Manx Pension Guarantee/Manx Double Lock was discussed and / or approved

Data Tables (5)

Full Response Text

Title of policy/procedure: Purpose of policy/proposal: Responsible Dept: Division: Person completing the EISA: Date: Sex/ Gender Religion or Belief Age Disability Race & Ethnicity Sexual Orientation Trans (Gender Reassignment) Pregnancy & Maternity Marriage & Civil Partnership No No No No No No No No No No No No No No No No No N/A No No Yes No No No No No N/A No No No No No No No No No No No No No No No No No No No No No No No No No No N/A No No No No No No No No No RESULT: PROCEED TO 'EQIA-FULL' - ONLY IF SCREENING INDICATES FULL ASSESSMENT NEEDED If a full Equality Impact Assessment is not needed, you have completed all of the impacts assessments in this tool. Proceed to Summary Report Full Equality Impact Assessment REQUIRED Financial Governance Division Is there any stakeholder concern in the policy about actual or potential discrimination? Questions to help you assess any positive, negative or unknown impact of your policy Is there any evidence that the different equality groups have different needs or issues in relation to the policy? Is there any potential, or evidence that, the policy may adversely affect equality of opportunity? Could this policy harm good relations for any of the equality groups? Is there any potential, or evidence that the policy could discriminate, directly or indirectly? If the impact has the potential to be significant, you should complete an EQUALITY IMPACT ASSESSMENT (below) using relevant data and/or consultation to inform your decision making BEFORE the policy decision is made.
END OF SCREENING ASSESSMENT Is there an opportunity to better promote either equality of opportunity or community relations by altering the policy? Is there evidence of physical access issues or non-physical accessibility issues (eg website access/documents)? • If you have answered “No” to all these questions, an Equality Impact Assessment is not required. • If your answer is “Yes” to any of these questions, then consider proportionality (resources available/impact on service users). For example, could you provide a lower standard of service to meet the needs of more users or offer a service on different terms to avoid negative impacts? Please state the rationale below for NOT proceeding with an Equality Impact Assessment Equality Impact Screening Assessment (EISA) Guidance notes are provided throughout by hovering over cells with a RED TRIANGLE in the top right corner. If you need more space, you can increase the height of the rows by dragging the markers on the left hand but please do not change the width of the columns. 2025/26 Annual Budget (Pink Book) Aims to support the economy, working families, low and middle earners in an affordable, responsible and sustainable way. The budget focuses on financial disipline and will require departments to ensure public services are delivered in an efficient way and within the bugetary allocation provided. Treasury Sarah De-Yoxall 10/01/2024 Title and purpose will auto-fill using data entered on the 'Details' tab, but you can over-write them if necessary. EQIAs make services better for everyone and support value for money by getting services right first time. It is also advisable to carry out EQIAs in a group to ensure that the assessment of the policy is not subjective. Details Title of policy/procedure: Focus of the EQIA: Responsible Dept & Division: Person completing the EISA: Date: Equality Impact Assessment (EQIA) (only complete if indicated by screening assessment) Guidance notes are provided throughout and are accessed by clicking for more information where indicated or hovering over cells with a RED TRIANGLE in the top right corner. If you need more space to answer any of the questions, please increase the row size by highlighting the row and dragging it larger using the left hand bar. Please do not adust the column width. EQIAs enable us to consider all the information about a service, policy or strategy from an equalities perspective and then action plan to get the best outcomes for staff and service-users. They help us make good decisions by considering and using robust evidence to inform decisions instead of making decisions based on assumptions. Before proceeding with an EQIA, you should have undertaken an equality screening using the Equality Screening above. If the outcome of this demonstrates a negative impact on protected groups, only then should you proceed with an EQIA. Change away from UK policy, removal of an increase at the higher of average earnings They analyse how all our work as a Government might impact differently on different groups. This section will complete automatically based on the information entered for your EISA; however, you can over-type it if necessary. Introduction of the Manx Triple Lock Social Security Division, Treasury Sarah De-Yoxall 10/01/2024 Update on previous EQIA and outcomes of previous actions, if applicable. N/A N/A N/A N/A What actions did you plan last time? (List them from the previous EQIA) What improved as a result? What outcomes have these actions achieved? State briefly what further actions you need to take? (add these to the Action plan below) Sex/ Gender Religion or Belief Age Disability Race & Ethnicity Sexual Orientation Trans (Gender Reassignment) Pregnancy & Maternity Marriage & Civil Partnership Human Rights Majority of pensioners are pre 2019 and not impacted by the measure N/A Summary of consultation Applicable to Post 2019 pensioners N/A The introduction of the Manx Double lock is to ensure equality across all ages meaning that all uplifts will be aligned to inflation Summary of data about your service-users or staff All potential actions to: ·   advance equality of opportunity, ·   eliminate discrimination, and ·   foster good relations Impacts identified from data and/or consultation Review of information, equality analysis and potential actions Protected characteristic Groups from the Equality Act 2017 N/A What do you know about your service user or staff? Click here for more information. What do people tell you? Click here for more information. What can you do? Click here for more information. What does this mean? Click here for more information. N/A N/A N/A N/A N/A N/A N/A Assessment of overall impacts and any further recommendations Action Plan Timeframe Ongoing Assessment complete EQIA sign-off Note: If you do not complete this field, the Summary Report will indicate that the assessment is incomplete.
Person responsible for EQIA: Sarah De-Yoxall Officer confirmation EQIA complete Use the drop down to indicate that the officer section of the assessment has been completed. If incomplete, leave blank. Note: If you do not complete this field, the Summary Report will indicate that the assessment is incomplete.
Evidence of data and/or consultation that informed your EQIA The impact of this is not significant given that the majority of pensioners are pre 2019. This measure promotes equality across all ages ensuring that benefit measures are aligned to inflation and this also protects the sustainability of the fund, to align contributions to expenditure. This action will support future pensioners ensuring fairness across the age population of the island. Did you identify any gaps in data? State what action you will take. Date Title (of data, research or consultation – add link or appendices) Social Security paper Dec-24 No What will you do to reduce or eliminate negative impact? Expected outcome Group affected Impact identified Post 2019 pensioners may possibly receive a pension that is lower than pre 2019 Post 2019 pensioners This will be monitored throughout the year by Treasury to assess the inflation and earnings data Little impact

Extract from the minutes of the meeting of the Treasury Board dated Wednesday 15 January 2025
006/25 Treasury: Sustainability of the Manx Social Security Scheme (Treasury Paper 25/024)

It was noted that an undertaking had been made to produce a document to explain the detail of
what was happening with the triple lock and, having explored the alternatives, the only alternative
(other than a double lock) was to increase National Insurance for working people.

Treasury concurred to the Government Document on the Future Uprating of the Manx State Pension
being submitted to the Council of Ministers.

Extract from the Treasury Paper referenced in the above minute, titled Sustainability of Manx Social Security Scheme, dated 15 January 2025 2. Future uprating of the Manx State Pension

2.1 Uprating of the Manx State Pension form April 2025

The document sets out that from April 2025 the Manx State Pension will be uprated by either Manx CPI referenced to the preceding September figure or 2% whichever is higher. The document does not state what the actual increase will be from April as this will be announced in the Budget as part of the usual benefit and state pension uprating orders.

Freedom of Information
Seyrsnys Fysseree

The Treasury Government Office,
Douglas Isle of Man, IM1 3PU

Telephone: (01624) 685605 Email: FOI.Treasury@gov.im

Government Website: www.gov.im

Our ref: 4438917 19 March 2025

Dear ###,

We write further to your request, received 11 February 2025 and amended 11 March 2025, which states:

"Please provide copies of the equality impact assessment, the equality impact screening document or any other assessment of the equality impact, or compliance with the equality act, in relation to the decision to end the triple lock / introduce the Manx Pension Guarantee/Manx Double Lock.

Please also provide copies of the meeting minutes where this policy to end the triple lock / introduce the Manx Pension Guarantee/Manx Double Lock was discussed and / or approved"

Our response to your request is as follows:

Equality Impact Assessment

Please find enclosed in Appendix 1 an Equality Impact Screening Assessment and an Equality Impact Assessment (EQIA). Please note that this screening assessment was not carried out specifically in relation to any decision to end the triple lock / introduce the Manx Pension Guarantee/Manx Double Lock. A combined climate, data protection and equality impact assessment was completed for the 2025/26 draft annual budget which considered all proposed budget measures and this resulted in a high level EQIA being completed for the introduction of Manx Double Lock, in relation to the Manx State Pension. (Please note the title of the policy/procedure within the EQIA is incorrect and should be ‘Introduction of the Manx Double Lock’.)

Meeting minutes

Please find enclosed in Appendix 2 an extract from a Treasury Board meeting where a Treasury Paper, which included a document detailing how the Manx State Pension would be uprated from April 2025, was approved and it was agreed the document would be submitted to the Council of Ministers.

Also included in Appendix 2 is an extract from the document referenced in the minute which set out how it was proposed that the Manx State Pension would be uprated from April 2025 i.e. the Manx Pension Guarantee/Manx Double Lock.

Please note the Manx State Pension will now be increased in line with the UK’s triple lock principle instead of the Manx Pension Guarantee/Manx Double Lock, whilst further consultation takes place.

Please quote the reference number 4438917 in any future communications.

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I will now close your request as of this date.