Anti-Racism Framework Guidance

Background

Australia’s report card on social cohesion shows us that while Australia is a celebrated multicultural country with 51.5% of the population being first and second-generation migrants, our sense of belonging is declining. Some describe this as a maturity issue – that Australia is a ‘young migrant’ country and lower social cohesion should be expected at this stage in the maturity curve.

Alarmingly, different racial and ethnic communities still experience racism and racial stereotyping on a regular basis in the community and in workplaces. Several recent research highlights that as many as 43–67% of racially diverse employees in Australia experience racism at work, aligning with MindTribes’ findings that 1 in 3 Women of Colour and 1 in 2 First Nations women feel culturally unsafe at work.

While the legislative framework, including the Racial Discrimination Act 1975, the Equal Opportunity Act 2010 (Victoria), and the Work Health and Safety (WHS) Act 2011, prohibits direct racial discrimination, these laws alone have not been sufficient to dismantle the underlying structures that perpetuate racism.

Understanding Systemic Racism

Systemic racism is deeply embedded in organisational structures and employment experiences, systems, and processes from “pre-hire to retire” in Australia. This perpetuates inequalities that disproportionately disadvantage First Nations people and racially and ethnically diverse groups.

This form of racism manifests through biased recruitment practices that favour certain racial groups, implicit biases in performance evaluations that hinder the career progression of non-White employees, and workplace cultures that subtly enforce conformity to the norms of the dominant racial group. These dynamics are often left unexamined, perpetuating exclusion and inequality within organisations.

The nature and context of the experience as recounted by thousands of racially diverse people, is that racial discrimination and racism are covert and subtle, making it harder to call out or formally report. 76% of women of colour shared that they experienced and witnessed racism but would never report it for the fear of not being believed and/or the resultant backlash to careers.

Why Anti-Racism in Organisations is Important, Now

Despite advancements in diversity, equity, and inclusion (DEI) initiatives over the past decades, deeper issues of racism are often not fully addressed, leaving significant gaps in organisational practices.

Overall, MindTribes’ practitioner work shows that a large proportion of DEI investment focuses solely on gender equality with little to no consideration of intersectionality (despite a significant proportion of the workforce being racially diverse) and low to no continued investment in race and ethnicity efforts.

While most organisations have matured their efforts in multiculturalism, from mainly celebrating key community dates (e.g., Eid and Diwali) to now collecting some data on languages spoken, ancestry, and countries of birth, often, we find the singular focus on multiculturalism has left no room for discussion on racism and race-based discrimination.

In fact, individuals often face internal conflict, like, “How can I raise racism experienced when I have just been asked to speak at a Valuing Cultural Diversity event and we have just had an Eid ball?” It is important to note that a person can experience both race-based discrimination and an appreciation of their cultural diversity by the same people in the same team. We find that senior leaders look to high engagement scores and multicultural events as a key indicator of success, while they often see race-based discrimination more broadly as bullying or harassment, questioning the veracity of whether it has anything to do with a person’s race. This discounting, disbelief, or dismissive responses and reactions mean that people’s voices are tentative or silenced.

Anti-racism goes beyond the passive act of upholding equality (under persistent structural, systemic racism) or refraining from discriminatory actions. It is a proactive approach that demands ongoing efforts to dismantle both systemic and behavioural inequities present in organisations and society as a whole.

At its heart, anti-racism acknowledges that racism is not solely an individual problem but is deeply rooted in societal structures, including employment systems. This perspective requires a shift from merely avoiding racist behaviour to active anti-racism, which entails deliberate actions to identify, confront, and eradicate racism from organisational practices, systems, and culture.

Current Regulatory & Governance Context

Government bodies are increasingly recognising the urgent need for organisations to go beyond complying with anti-discrimination laws and actively engage in dismantling systemic racism. The Australian Human Rights Commission (AHRC) is developing the first National Anti-Racism Framework, the Victorian Government’s Anti-Racism Taskforce is crafting a state-wide Anti-Racism Action Plan, the Victorian Equal Opportunity and Human Rights Commission (VEOHRC) recently published a guideline for organisations to meet minimum standards on proactive duty to eliminate racism, and the New South Wales Public Sector Commission (NSW PSC) also recently published an Anti-Racism Guide on fostering anti-racist workplaces in the NSW public sector. These initiatives represent a significant upcoming shift in Australia’s approach to acknowledging and addressing racism.

The broader social and political context, both within Australia—such as the discussions around the Indigenous Voice to Parliament—and globally (including human rights violations and human suffering from conflicts like in Israel and Palestine, Russia and Ukraine, and the civil war in Sudan), further highlight the need for organisations to be prepared to respond to these challenges. This response is essential not only to fulfil legal duties of care but also to meet Environmental, Social, and Governance (ESG) responsibilities amidst an increasingly complex social justice landscape.

About This Report

At MindTribes, we have been engaged by numerous organisations across public and private sectors in recent years to deliver on anti-racism work, reflecting a growing recognition of its importance. It is, however, to be noted that in all our client work, we have had to advocate and influence with a key senior ally to convince others that this work is critical.

Typically, it has involved an initial request about anti-racism, racism, and more often cultural diversity. We use this opportunity to extend the discussion to the systems, risks, and duty of care. Together with an influential executive in People and Culture or a business leader sponsoring the work, we influence and advise on the most appropriate starting point to create an impact, and then we partner to sustain the change.

We have found that where organisational policies and frameworks are inadequate to address deep-rooted biases and inequalities, they result in a sunk cost of existing investments and efforts.

This report distils our learnings as practitioners, combined with evidence from qualitative and quantitative research, to provide practical, actionable guidance for organisations embarking on or continuing their anti-racism journeys.

We build upon existing evidence including AHRC Leading for Change Revisited Report (2018), DCA Racism at Work Report (2022), Australian Government’s Towards Fairness: A Multicultural Australia for All Report (2024), Victoria University’s Understanding Reporting Barriers and Support Needs for Those Experiencing Racism in Victoria (2024), VEOHRC’s Guideline: Race Discrimination in the Workplace (2024), Media Diversity Australia’s Racism Handbook (2024), and more.

Our goal is to offer best practice insights that support the development and implementation of effective Anti-Racism Frameworks, ensuring they are both impactful and sustainable. It is intended to be complementary to the work completed by the government and other bodies, by taking a practitioner lens and widening the scope to cover all organisations in Australia.

Summary Guidance

Drawing upon findings from this research, as well as MindTribes’ decade-long practitioner experience with Australian organisations, we have identified and ranked by priority ten key considerations that should be taken into account in the development and implementation of Anti-Racism Frameworks. Importantly, these factors are interconnected and interdependent (as shown in Figure 1).

1. Leadership – The Extent to Which Leaders Are Committed to Addressing Racism

Leadership actions and commitment can make or break an organisation’s anti-racism efforts. Leaders have the organisational and positional power to role model, make decisions, set priorities, allocate resources, and set the standard for the rest of the organisation.

We have found that when leaders lack a shared authentic understanding and strong commitment to the anti-racism efforts being implemented, they create inconsistencies between what is preached and what is practiced, leading to further embedding of negative behaviours and processes within the organisation. As senior leaders set the priorities for their leadership cohorts, efforts tend to be sporadic and not sustained – if they speak less about cultural diversity, race, and ethnicity, there is a corresponding loss of focus.

However, when leaders’ actions are measured formally, such as in their performance and development plans, we find that there is transparency and accountability across the leadership levels. As this seldom happens, efforts from leaders are often hit or miss – some well-intentioned, determined leaders will follow through, while others will not. If the impact of leader action on gender equality is used as a standard for anti-racism action, then we should also have targets, KPIs, and transparent reporting on progress, year on year, for anti-racism.

We see a reluctance to follow this path of organisational and leader accountability because leaders often have low racial literacy and a lack of comfort with this agenda.

MindTribes Example

When the outcome of racism listening sessions was delivered to a CEO and the CPO of a large private sector firm, the CEO’s first response was to question whether this was truly representative of all racially and ethnically diverse people, suggesting that it might be a smaller problem than portrayed. The CEO expressed concern about the perceptions of board members, shareholders, and the possibility of the media branding the organisation as racist. He indicated a preference to defer any programs or initiatives until a more stable time for the business.

This CEO has since shifted his position and is now a public ally and advocate. The qualitative data report derived from the listening sessions played a crucial role in influencing him to act almost immediately.

2. Racial Literacy – Understanding and Improving the Racial Literacy of Different Employee and Leader Groups

The MindTribes Racial Literacy Framework (page 40) is designed to assess and develop individuals’ understanding and skills related to race, racism, and anti-racism within an organisational context. It categorises racial literacy into four levels, ranging from racially illiterate, basic, intermediate, to advanced proficiency.

We recommend organisations mandate basic racial literacy as a minimum standard for all employees, with leaders encouraged to achieve higher levels to act, lead, and foster a workplace environment that is anti-racist. Organisations should consider the current racial literacy of their audience when designing communications and initiatives while putting in place frameworks to enhance the racial literacy of their people and the racial maturity of the organisation as a whole.

Without adequately identifying and tackling low racial literacy, organisations risk implementing one-size-fits-all initiatives that may not address the most pressing issues (e.g., attitudes and behaviours from those who are racially illiterate), leading to disengagement or even backlash. In our experience, leaders who are racially illiterate risk causing significant psychological harm as they make decisions with unchecked racial bias and negatively influence the workplace culture. Effective anti-racism frameworks must incorporate racial literacy into employee learning journeys and change management initiatives.

MindTribes Example

An established staff-led network put forward their activity and plan for the year ahead to their sponsor [a member of the senior leadership team]. This plan included anti-racism learning for the senior leadership team and initiatives that created spaces to talk about racism.

The people and culture lead and the senior sponsor asked the Chair of the network and the executive team to remove any references to race, racism, and anti-racism as they felt that the organisation and leadership team were not ready to receive this kind of information. They would not endorse the plan until this language was removed.

They asked the Chair to use ‘cultural diversity’ and to promote ‘multiculturalism’ as the core purpose of the network and “not to go too deep” into negative behaviours. The people and culture team shared that they would consider carrying out organisational learning on racism and racial discrimination when the timing was right.

3. Resourcing – The Extent to Which Resources Are Allocated for Delivery of Initiatives Within an Action Plan

Adequate resourcing is fundamental to the success of any anti-racism strategy or action plan. Organisations must ensure that sufficient time, budget, materials, and expertise are allocated to support comprehensive and sustained efforts, rather than relying on employees’ voluntary contributions, which are often added on as extra tasks.

Proper resourcing enables thorough planning, execution, and ongoing support, ensuring that anti-racism measures can achieve meaningful and lasting change. Without these resources, initiatives are likely to be superficial and short-lived, failing to address deep-rooted issues effectively and potentially backfiring.

Currently, based on MindTribes’ experience, a large proportion of the effort in anti-racism and cultural diversity efforts is voluntary, driven by staff-led networks or employee resource groups. These are individuals with lived experiences of racial discrimination who use their voices to advocate for change, even as their experiences and cultural capabilities are regularly devalued. Persistent lack of resource support from the organisation risks burdening the very people anti-racism efforts are intended to support, leading to cultural burnout and further harm to those with lived experiences.

MindTribes Insight

Since the death of George Floyd in 2020, MindTribes has seen a marked increase in the formation and growth of staff-led networks/ERGs for People of Colour, Women of Colour, and CALD groups. They often see no or low funding (maximum $5–10K a year). Of the DEI work focusing on diverse identities (women, race and ethnicity, gender, LGBTIQA+, First Nations, and Disability), we note that race and ethnicity work receive the lowest funding, often engaging in a race to the bottom with Disability and First Nations work.

This is disheartening, given the workforce representation of 15–30% of CALD people in most private and public sectors. Overall, DEI resourcing is low and often is an added portfolio to an already stretched people and culture leader or allocated to a part-time FTE who has no budget or extra resources. Projects often involve small pieces of work contracted piecemeal, with suppliers having to go through long and expensive procurement journeys and business casing, leading to a lack of continuity of funding and connection to the greater strategy.

4. Governance & Accountability – Oversight and Responsibility for Anti-Racism Initiatives

Appropriate governance and accountability are essential to ensure that anti-racism initiatives align with an organisation’s values, legal requirements, and ethical standards. Proper governance establishes the frameworks and oversight needed to ensure that initiatives are implemented with integrity and transparency.

We have advised clients to approach governance through the lens of Principles (ethics), Process (structures, roles, risk, operations), and Performance (accountability, measures, and evaluation). Due to the low maturity and sporadic nature of anti-racism work, we often find a lack of an ethical purpose explaining why the work is necessary. Additionally, there is frequently no one person who is overall responsible or accountable, meaning that no one is truly managing the risk of inaction. Operationally, there is often an absence of a smooth flow of initiatives that combine to drive structured change.

Governance of the Anti-Racism Framework should be adequately incorporated into existing organisational management systems and processes, including clear reporting pathways (linked to Resourcing as mentioned in point 3). Leadership within an organisation should be personally accountable for the success of these initiatives, given the significant role they play (as described in Leadership Actions and Commitment, point 1). We recommend incorporating oversight mechanisms and regular reporting processes, with clear accountability tied to the performance of responsible leaders.

MindTribes Insight

We have found that there is a significant issue with governance more broadly in DEI work. In an organisation, there are often many stakeholders who are not always connected to or keenly aware of the key objectives of proactive prevention and responding to early indicators of harm.

We often see poor governance regarding responsibilities for policies, learning, mental health, reporting and responding to complaints, staff-led network support, and senior leader capability. This poor governance also extends to reporting, which tends to focus on milestones and activity. Too often, organisations—if they report at all—only report on what was done rather than whether the initiative achieved the desired outcomes.

5. Internal Communications – Ensuring Employees Understand and Follow the Anti-Racism Action Plan

Clear, consistent, and effective internal communication is crucial for creating awareness and fostering a desire for change among employees, aligning with best practice change management principles. All employees should understand the necessity of the anti-racism action plan, the specific issues it addresses, and feel motivated to support and engage with the plan. Regular communications also support transparency, building trust and authenticity in the organisation’s purpose and activities.

A lack of clear definitions and objectives often creates barriers to implementation, as varying perceptions of racism and anti-racism can hinder progress. Without employee awareness and motivation to drive change, anti-racism initiatives risk failing to gain traction and achieve meaningful outcomes. Internal communications are closely tied to racial literacy (#2) and leadership (#1), making these foundational elements critical for effective communication strategies.

MindTribes Insight

We often find that communications to promote an anti-racist culture is not evident. Communications tend to be activity based or core message based (e.g. Stop Racism) and therefore are not continuous. This lack of continuity does not normalise the language and meaning around racism, racial discrimination and anti-racism. This often results in shock when some race-related messaging eventually comes out. We often hear of the backlash to the initiatives, such as questioning why there is a need to talk about racism because “Australia is so multicultural,” asking why the language refers to people’s skin colour, such as People of Colour, and questioning, “Who does this refer to and is this not more suited to America?” or stating, “I am from a different cultural background and have never experienced racism in all my years, so I don’t think it is a problem here.”

Based on insights from the maturity journey of gender equality, internal communications, event and learning must be regular, bringing people along on a change journey. This ensures that no matter where their attitudes and beliefs start, they understand that the organisation’s values and behaviours are aligned to gender equality (in this case, anti-racism). This approach of mainstreaming the discourse is lacking as there is no regularity of communications with racial discrimination and racism, nor anti-racism.

6. Employee Voice – Incorporating Employees’ Lived and Living Experiences into Anti-Racism Initiatives

The lived experiences of employees (past experiences) and living experiences (current experiences), especially those from marginalised groups, provide essential insights into the realities of racism within the organisation. Anti-racism initiatives must be guided by employee voices that are not only heard but actively incorporated into decision-making processes.

By creating safe spaces for employees to share their experiences and ensuring that this data is acted upon, organisations can build trust, foster engagement, and establish a feedback loop for continuous improvements. This approach elevates diverse voices, promotes agency, and ensures that anti-racism initiatives are relevant, impactful, and effective.

MindTribes Insight

We are often concerned that organisations run focus groups and consultations with staff to ask about their experiences of inclusion and respect when considering their racial and ethnic identities, without proper safety and risk protocols, including any duty of care post-sharing these experiences. We find that when data is collected and racially and ethnically diverse people willingly share what they would like to see improved, nothing significant is done to see this realised. This creates a backlash of low trust and faith in the organisation and leadership, often doing more harm than good.

MindTribes has a well-honed and well-respected process of engaging with people to gather lived and living experience data. We ensure that pre-, during, and post-racism listening, we manage safety, risk, and support of staff—only taking on this work if we are able to share the behavioural insights and recommendations report with the C-suite and board, who can follow through by acting to improve people’s experiences.

We often recommend a regular method and process that includes people’s voices in the design of employee experience surveys, providing more depth to the response data. Importantly, it is worth noting that listening sessions, focus groups, and consultations are data collections at a “point in time.” The voice of employees needs to be at the core and consistently present. Staff-led networks often provide a good reference group for the continuous employee voice.

7. Initiatives – Prioritised Actions Aligning with the Maturity Curve and Organisational Readiness

The correct selection and sequencing of activities, based on change management principles, are critical to the successful implementation and outcomes of an anti-racism action plan. Interventions should be evidence-based, context-specific, and fit-for-purpose for the organisation’s unique scenarios. The sequencing and timing of activities must also consider the change readiness of people leaders and employees, their knowledge and racial literacy (linked to point #2), and the urgency of the issues. The MindTribes Anti-Racism Maturity Curve provides guidance on the recommended phasing of initiatives that align with the organisation’s maturity and readiness to act.

Without strategic selection and sequencing, interventions may be disjointed and ineffective, leading to inefficiencies and failing to achieve the intended outcomes. Sporadic and poorly considered initiatives that are not viewed through a change management lens can sometimes have a deleterious effect, contrary to their intended purpose.

MindTribes Insight

Often owing to the lack of maturity in the market on racism and anti-racism, we find organisations replicating what their competitors are doing. When we have engaged with clients in early conversations about what they think they need, they often reference other competitors in the sector and, as a result, ask for education and awareness (e.g., a workshop or learning program). They have not understood the lived experience of people in their own organisations, with little to no understanding of the key issues, barriers, biases, and psychosocial risks to then design initiatives that target the problem.

Instead, the initiatives tend to be interpersonal-related, broad, with no real change to the lives of people or the systems they operate in. Overall, planning (forecasted initiatives for 12 months) is poor—often it involves reactive initiatives with little interconnectedness and change management.

8. Impact Measurement & Monitoring – Measuring and Monitoring Racism and Action Plan Effectiveness

A robust data collection, monitoring, and reporting system is an important enabler for the long-term success of Anti-Racism Frameworks. Impact measurement refers to assessing outcomes, such as the reduction or elimination of racism, while monitoring involves tracking and evaluating activities that contribute to achieving those outcomes.

Appropriate indicators of both implementation and outcomes must be identified as part of the Anti-Racism Framework. An effective monitoring and reporting system helps track the prevalence and experiences of racism longitudinally across the employee lifecycle, evaluate the effectiveness of measures, and ensure initiatives remain on track. Regular measurement and articulation of impacts also enable consistent internal communication of progress to employees, fostering trust by demonstrating the organisation’s commitment to addressing racism.

In the absence of monitoring and reporting, initiatives often lack direction and accountability, leading to a loss of momentum and undermining their effectiveness. Impact measurement and monitoring are closely tied to governance and leadership accountability, ensuring clarity on who is responsible and accountable for the progress and outcomes of anti-racism initiatives.

MindTribes Insight

What we find is that organisations seldom have either, i.e. no tracking and evaluation of activities and no real impact/outcome measurement. Even if they have some tracking and evaluation, it is low-level tracking, for example: how many people attended an anti-racism workshop instead of how many people made a commitment to apply the learning to create an anti-racism team culture (what we recommend). We also strongly recommend that this is captured in a development plan that is tied to values or behaviour scores of leaders.

In the example, the latter recommended approach ensures movement towards the outcome; the former attendance-type data is often meaningless. Specifically for anti-racism work, impact measurement is key as the work required is longitudinal but is most likely starting as an inaugural piece of work, which means the planning and activity tracking to mobilise change is a long road.

9. Employee Wellbeing Support – Embed Cultural Safety in Day-to-Day Operation and Management; Supported by Culturally Sensitive and Accessible EAP

Employers are responsible in proactively maintaining psychological safety and cultural safety in the workplace. Racism has a devastating impact on racially and ethnically diverse employees.

Cultural safety must be embedded into everyday workplace experiences. Additionally, managers and employees need to be trained to respond sensitively to concerns about racism, ensuring both psychological and cultural safety in the everyday workplace.

Organisations should also ensure that Employee Assistance Programs (EAPs), including mental health and well-being promotion services, are culturally sensitive and accessible to address the unique challenges faced by marginalised employees.

MindTribes Insight

The mental health, well-being, and clinical psychology services industry has historically operated through a White-lens, rooted in university education and perpetuated through practical training and the types of organisations therapists and counsellors join. Suppliers contracted to large organisations are typically not representative of workforce demographics and, as we often observe, do not invest in culturally responsive capability training.

Concepts of self-care from a Western perspective—such as who and how a person connects to support systems (e.g., family or kin)—differ significantly when considering First Peoples, migrants, refugees, and asylum seekers, even in second generations. Care is often individual-focused and self-management-driven, whether in health promotion or incident response. This approach neglects the collective way that many from culturally diverse backgrounds maintain their mental, emotional, and physical health.

Mental health and well-being practitioners are often not skilled in addressing racism and racial discrimination. Consequently, when organisations embark on anti-racism work, the lived and living experiences of individuals are exposed, leaving them vulnerable. These individuals may experience further harm if support services lack the capability to provide culturally responsive care.

10. Public Sentiment – The Influence of Public Sentiment on the Promotion and Perception of Anti-Racism Measures

Public sentiment is generally shaped by the broader social and political context, industry-specific consumer segments, and the social license of the organisation.

To effectively manage public sentiment around anti-racism initiatives, organisations should first focus on internal communications and culture. This involves cultivating an inclusive environment from within by engaging employees, fostering open dialogue, and ensuring all internal stakeholders are aligned with the organisation’s anti-racism goals. This internal alignment ensures that any public expression of the company (e.g., marketing, communications, slogans, sponsorships) authentically reflects the internal dynamics, preventing the organisation from being perceived as hypocritical or insincere.

While the design and rollout of anti-racism initiatives should be considerate of public sentiment, organisations must manage communications strategically, balancing transparency with sensitivity to prevailing attitudes. Authentic and transparent communications, aligned with organisational ethics, can prevent the organisation from appearing disingenuous or reactionary.

MindTribes Insight

We have seen Australian organisations deliberate over their positions on marriage equality, the Voice referendum, Black Lives Matter movement, climate change pressures etc. They are typically in a balancing act with stakeholders, over the public position they should take and how firm and clear they should be.

Usually, there is some scenario planning i.e. considerations for the potential negative backlash to the brand’s reputation, shareholder value, customer loyalty or loss. Ultimately these positions are taken, more in consideration of commercial, customer, and the competitor lens than primarily ethics and morality.

Organisations, commercial considerations need not be at odds with their ethical and moral obligations. Often the “right thing to do” aligns with their customer and employee expectations. Conversely, maintaining the status quo could result in negative brand impacts, poor attraction of talent and consumer backlash.

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