Dear Ms Rose
I write to you as CEO of the NatWest Group to express a number of concerns arising out of NatWest’s response to the Women and Equalities Committee on 26th November 2020. This letter is signed by a number of others, many of whom are customers of NatWest and who have indicated this status by the letter ‘C’ next to their name.
The response said this:
NatWest Group supports a review of the identity rules in the UK to reflect the needs and rights of trans and non-binary people. … Society is a diverse place with many kinds of people who are all unique. Making it easier for people wishing to change their gender status would help to safeguard the physical, mental and emotional wellbeing of trans people, and continue the journey towards social and legal equality…. NatWest Group believes that no individual should be placed under any additional burden, be it emotional, physical or financial, to be able to be who they are. .. We support the adoption of a self-declaration system for legal gender recognition in the UK. We have already adopted this process in the workplace to ensure that colleagues can bring their whole selves to work every day, free of judgement, as part of our goal of ensuring all our staff are comfortable in their surroundings. We also extend the same levels of support to our trans and non-binary customers, enabling customers to self-declare gender changes with no requirement for additional evidence.
This raised immediate concerns given the significant risks that ‘Self ID’ will impact negatively upon the safety and dignity of women, given that between 80-90% of self declared transwomen make no modification to their bodies by either way of medication or surgery.
To be fair, the response does to on to say that changes to the GRA require further clarification to ensure ‘equal’ protection of all protected characteristics:
… we would ask the inquiry to consider how these changes could be balanced against the need to protect the rights of others. We believe it remains essential that all the protected characteristics remain equally protected as enshrined in the UK Equality Act, 2010…. NatWest Group believe that further clarification and/or guidance would be helpful to employers and to ensure that employees and service users are aware of their rights.
However, it is difficult to see how ‘all’ protected characteristics can be ‘equally protected’ if you have already instituted ‘self ID’ in the workplace, or among your customers. Quite apart from any issues of increasing exposure to fraud and ID theft, this permits any man to claim he is a woman on his assertion alone. I can see no reference in this response to the nature or degree of consultation, if any, that was carried out with your female employees or your female customers about the impact of this policy on their ability to ‘bring their whole selves to work’ or be confident that their ‘physical, mental and emotional wellbeing’ is protected whilst on your premises.
This is particularly concerning when I look at your ‘gender balance’ policy, which is committed to ensure ‘at least 30% women in our top three leadership layers (c.4,000 roles) in each of our businesses by the end of 2020 and achieve a full gender balance across the bank by 2030.’ What definition of ‘woman’ will you be using to secure this aim? Presumably none whatsoever, as you have already adopted and implemented ‘self ID’ throughout NatWest.
I raised my concerns initially with the Twitter account @NatWest_Help on January 13th 2021 which invited comment via Direct Message. I said:
Dear NatWest. I have been a customer of yours for over 30 years. But given the astonishing content of your recent submission to the WEC about your support for the rights of men to become women on their declaration alone, I will now have to reconsider this position as a matter of urgency. I am particularly worried by the fact your submission could not even bring itself to use the word ‘sex’ or recognise the importance of retaining single sex spaces for the dignity and safety of women and girls. I do not understand why you feel it appropriate or necessary to join the debate in this way.
I received a response from ‘Barry’ later that day.
Hello Sarah. We’ve provided input into a consultation on legislation that is currently under review. In doing so, we consulted with our LGBT+ colleagues and took account of our shared value of supporting individuals to bring the best of themselves to work, a privilege often not afforded to Trans* individuals. As an entity, NatWest Group is comfortable to contribute to the consultation, recognising that it is in line with our inclusion principles, one of which is that we do not support views that undermine protected characteristics and/or minority and under-represented groups. It is true that – with inclusion – we cannot always share the same views as each other, but as an organisation, we are comfortable to support our Trans* colleagues and customers this way. ^Barry
I would be grateful if you could explain the extent of the impact assessment you conducted with regard to the consequences for women in your organisation, and also women who are your customers. Which women did you consult? To what extent did you satisfy yourselves that support for Self ID would not undermine the protected category of sex and the safety and dignity of women?
At the time of writing I have had no response to these questions. Such is the serious nature of my concern that I write to you now.
I have been a long standing customer of NatWest. I do not relish the prospect of moving my accounts and mortgage product to another provider. However, I am very concerned by what I have read and the nature of the responses. I would like to be reassured as to the nature and degree of the consultation carried out with women in to inform the implementation of this policy of ‘Self ID’ and some understanding as to how you intend to mitigate the obvious and serious impact this will have on women who are either employed by or customers of the NatWest Group.
I would be grateful for a response within 28 days.
- Dr Carly Brooks
- Tanya Carter
- Jason Clark
- Diana Clough
- Margaret Court
- Lawrence Cox
- Alix Goldring
- David Gourley
- Jennifer Gourley
- Donna Hughes
- Sarah Johnson
- C. Moravec [C]
- Louise Paine on behalf of LAWS (Let A Woman Speak)
- Sarah Phillimore [C]
- Beth Miller
- C.L. Mulholland
- Alison Simmons
- Carla Thompson
- Georgia Thompson
- Charlotte Wells
- Tracy Woodley
- Colonel (Retired) S.A. Winkworth CMgs FCMI FInstRE [C]
- Mina Znaidi