Gender commitments, built so that someone can check them
Signing a set of principles takes an afternoon. Showing a monitoring team a grievance record, a promotion analysis and three years of cohort data takes a programme. We build the second thing, and we write the first so that it matches.
Who asks for this, and what they ask for
Almost nobody commissions this work because of a slide about diversity. It arrives through one of two doors. The first is disclosure: a sustainability statement has an own-workforce section, and that section needs numbers rather than intentions. The second is finance: a due diligence or a labour audit has found a gap against a lender standard, and the loan documentation now carries an action plan with dates in it.
Both doors lead to the same building: a policy that exists, a mechanism people use, decisions with a record behind them and a figure that moves year on year. Scope and timing on the reporting side are covered in our CSRD and ESRS guide.
What the standards actually say
IFC Performance Standard 2
Fair treatment, non-discrimination and equal opportunity of workers is one of the standard's stated objectives. Paragraph 15 requires employment decisions to rest on equal opportunity across recruitment, compensation, training, promotion and termination, and requires measures to prevent and address harassment, intimidation and exploitation, especially in regard to women. Paragraph 20 requires a grievance mechanism for workplace concerns, with prompt handling, no retribution and the option to complain anonymously. Scope is where most gap lists get written: the requirements reach direct workers, contracted workers and primary supply chain workers, with separate paragraphs for each, so a policy that stops at the contractor gate does not meet the standard.
EBRD Environmental and Social Requirement 2
The EBRD Board approved a new Environmental and Social Policy on 20 December 2024. It supersedes the 2019 policy and renames the Performance Requirements as Environmental and Social Requirements, so a term sheet referring to PR2 points at the predecessor of what is now ESR 2. Its objectives include fair treatment, non-discrimination, non-harassment and equal opportunities for all project workers, and name women and gender-diverse workers among those at higher risk of discrimination, harassment or exploitation.
Two paragraphs decide most engagements. Paragraph 34 requires specific measures against gender-based violence and harassment (GBVH), with adequate expertise, regular training and codes of conduct. Paragraph 39 requires the grievance mechanism to handle complaints needing special protection through a survivor-centred approach: safety, confidentiality, support options and anonymous reporting. The Bank's Equal Opportunities Strategy and Strategy for the Promotion of Gender Equality sit outside this requirement, which is worth knowing before a negotiation conflates them.
The Women's Empowerment Principles
The Women's Empowerment Principles (WEPs) are seven principles established by UN Women and the UN Global Compact, covering high-level leadership, fair treatment at work, health and safety, education and training, enterprise development and supply chain practices, community advocacy, and measurement and reporting. A company joins through a statement of support signed by its chief executive. That is a commitment rather than a compliance document, and the seventh principle is the one that keeps the other six honest.
ESRS S1, if you report under the ESRS
ESRS S1 covers your own workforce. Diversity and equal treatment is one of its sub-topics, and gender distribution at top management is among the metrics it asks for, which turns the subject from a statement into a number that either moves or does not. Whether S1 is material for you is a question for your materiality assessment rather than for a service page.
How an engagement runs
- Diagnostic against the standard that applies Policy and procedure review, workforce data, interviews at more than one level, and a look at how the grievance mechanism is actually used. The output is a gap list written against a named standard, not general good practice.
- Gender action plan Every gap becomes an action with an owner, a deadline and a test for when it is closed. This is the document annexed to the financing, so it is written to be closed out rather than to look ambitious.
- Policy, procedure and mechanism work Non-discrimination and harassment provisions that reach contracted workers, codes of conduct, training, and grievance handling a person can use without putting themselves at risk.
- Development programmes The modular formats below, chosen against the objective rather than the budget cycle, and run for cohorts rather than as one-off events.
- Measurement and reporting A baseline before anything starts, comparable measurement afterwards, workforce indicators tracked in your normal reporting cycle, and the findings written for whoever asked: a board paper, a lender monitoring report, or the own-workforce section of a sustainability statement.
The development programmes
Time is not the only measure of change. The formats run from an hour to six months and are modular on purpose: awareness becomes skill, and skill becomes leadership that holds once the consultants have gone.
| Format | Length | What it does |
|---|---|---|
| The Spark | 1 hour | Fast awareness, and self-leadership lit |
| The Core | 2 days | Resilience and strategic interaction |
| The Flow | 1 week | Agile problem solving and forward momentum |
| The Transformation | 1 month | Habits and working life realigned |
| The Legacy of Master Academy | 3 to 6 months | Leadership internalised, not borrowed |
What we deliver
Workforce data is collected alongside the rest of your sustainability reporting data.
- Diagnostics against IFC and EBRD labour requirements, and gap lists written to be closed.
- Gender action plans with owners, deadlines and completion tests.
- Non-discrimination, anti-harassment and GBVH policy, procedure and training.
- Grievance mechanism design, including survivor-centred handling.
- WEPs implementation plans and progress reporting.
- Diversity, equity and inclusion (DEI) strategy and corporate capacity building.
- Women's leadership programmes in five modular formats.
- Measurement and evaluation frameworks, and the workforce data behind them.
Why Etki Fabrikası
Our consultants have more than twenty years of advisory experience across banking, mining, energy, food and retail, and in five years we have worked with over forty corporate brands on more than ninety projects. Gender work sits in the same team as our environmental and social due diligence practice: the labour requirement a lender enforces and the disclosure a group prepares draw on one evidence base.
One example from the field. At the Muratdere mining project in Bilecik, the community development programme included Women's Labour, Women's Power: a women's cooperative with a production centre and support for the village shop, training, and the sales and marketing steps needed to get micro-production off the ground. That is the version of this work we prefer, because someone can go and look at it.
Where your value chain reaches Türkiye and the countries around it, the same consultants run the interviews on site, in the language the workforce speaks. Evidence gathered through an interpreter on a flying visit reads thinner later, in a monitoring mission.
Frequently asked questions
What is a gender action plan, and who asks for one?
A time-bound plan that converts the gender-related gaps found in an assessment into actions with an owner, a deadline and a completion test. It is usually asked for by a lender applying its standards, after a due diligence or a labour audit has found something: a grievance mechanism nobody uses, no measures against harassment, promotion decisions with no record behind them. It is worth having without a lender too, because it is the only format in which a commitment can be checked.
We have signed the WEPs. Is that enough for a lender or an auditor?
No, and it is not meant to be. The Women’s Empowerment Principles are a commitment framework established by UN Women and the UN Global Compact, signed by the chief executive. Lender standards ask for something different: a policy, a procedure, a mechanism people actually use and evidence that it works. The two fit together well, because reporting on progress is the seventh principle, but a signature closes no requirement on its own.
Do these programmes only involve women?
The focus is on women in the organisation, but the change is not confined to them. An inclusive culture depends on the allyship of male managers, on leadership behaviour changing and on systemic mechanisms being built, so modules run mixed or at management level where the objective requires it. Leaving the decision-makers out produces a well-trained group of women inside an unchanged system.
How do you measure whether any of this worked?
Two layers. Programme outcomes are measured before and after against psychological safety, burnout, engagement and wellbeing, and expressed through a Trust Score, a personal Manifesto and Cultural ROI. Workforce data sits underneath: representation by level, hiring, promotion and exit rates by gender, access to training, and grievance volumes and resolution times. The first tells you whether the programme landed; the second is what a disclosure or a lender review asks for.