1.1 The TUC represents 58 affiliated trade unions with nearly 7 million members. Trade union members work in a wide variety of organisations, sectors and occupations and come from a diverse range of backgrounds. Our affiliates regularly represent women workers suffering from the impact of violence, and they work with employers in raising awareness of violence against women and developing related policies and practices.
1.2 The TUC has campaigned and lobbied on the need for an integrated strategy on violence against women (VAW) as member of the End Violence Against Women Coalition. It believes that the high priority that the Government has placed on tackling domestic violence has been lessened by a contradictory and fragmentary approach and the lack of a broader understanding of 'violence against women'. Furthermore, the lack of an integrated approach has also prevented effective links being made with the Government's work on trafficking, sexual exploitation and women within the criminal justice system.
1.3 The TUC therefore welcomes the recognition by the Government within this consultation on the need for an integrated strategy and the use of the UN definition of VAW. In making this response, the TUC endorses the submissions made by the End Violence against Women Coalition (EVAW) and those by TUC affiliates. We follow EVAW in asking that this response be read in conjunction with the 'Realising Rights, Fulfilling Obligations' template integrated strategy and 'Map of Gaps 2'. Rather than addressing each of the specific questions, this response will focus on the broad themes that the consultation identifies. Where the TUC has not responded to areas covered in the consultation, it refers the Home Office to the submissions made by trade union affiliates and EVAW.
1.4 Violence and its effects both short-term and long term is found in all aspects of our society. The TUC and its affiliates are therefore concerned that the consultation document is largely silent on the workplace as an arena where women can experience violence and sexual harassment. Affiliates with members working in a wide variety of sectors - from the shop floor to schools and colleges reported that many women experienced sexist bullying, harassment and assault as part of their work. They frequently found that incidents were not appropriately dealt with and that their safety was not given priority. The TUC believes that any discussion about violence against women, bullying and respect should cover the workplace. TUC surveys regarding the experience of women workers and trade union representatives have also highlighted the way that VAW experienced in the home can affect women at work and the role that union representatives and employers can play in supporting women affected by violence.  The TUC believes that awareness raising amongst employers of the impact of violence against women in the workplace and encouraging the provision of appropriate support, in consultation with trade unions, is critical.
2.1How should schools encourage young men to treat women and girls with respect and not resort to violent behaviour?
2.1 The TUC has conducted surveys of women trade unionists on their views and experiences of violence against women. Amongst the key findings and recommendations of the resulting report, 'Breaking the Silence on Domestic Violence', published in May 2002, was the need for young people to be taught about issues relating to VAW through the National Curriculum and through school discussion.
2.2 This view is shared by those TUC affiliates who represent the school workforce, including the teacher unions, who are also submitting their own responses to this consultation. They believe that young people welcome opportunities to talk about an issue which they sometimes have direct experience of, and might feel confused by. The NUT reports that young people often find it easier to talk such issues to their friends than to adults and that discussing the issues together may be their favoured way of learning. The NUT goes on to argue that 'schools are perfect places to work with children and young people while they form their ideas about relationships. The aim should be to prevent violence from being a feature in their lives, rather than to intervene after the event'.
2.3 The TUC and its affiliates believe that a 'whole school ethos' is vital in encouraging respect for women and girls and in tackling violence against women. Mutual respect, rights and responsibilities and gender equality can be delivered throughout the curriculum. While Personal, Social and Health Education provide opportunities to tackle issues of respect and gender equality, it can also potentially be delivered through most subject areas. The NASUWT believes that while specific and discrete curricular work to tackle violence against women and children and promote healthy relationships is critical, it should be embedded and delivered throughout the curriculum to prevent an incoherent approach. Appropriate training and support for all members of the school staff will be critical in delivering a 'whole school' approach to tackling VAW, including the identification of domestic violence and sexual violence as well as procedures for sensitive and confidential handling of such matters. However, it is important that Sex and Relationships Education should be delivered by people who have the specific training thereby recognising both its importance and that it is a subject area requiring specialist knowledge and skills.
2.4 The NUT identifies a number of ways schools and colleges can approach these issues through the wider curriculum, including:
- concepts of power within relationships and how these can lead to violence in the home;
- address gender stereotypes that continue to define and shape behaviour, characteristics and skills;
- discuss ways of making relationships work effectively, including the need for communication and listening;
- inform pupils about the range of organisations and agencies who can assist victims of domestic violence;
- provide insight into the reasons why women can be forced to stay with violent partners;
- tackle sexist bullying and name calling.
2.5 Teacher union affiliates have reported that school anti-bullying policies do not always highlight or explicitly mention gender-based bullying and believe that explicit reference to sexist bullying would be helpful. Bullying experienced by boys can often compound sexist attitudes towards women as well as homophobic attitudes. The NASUWT has welcomed plans to require schools to report different forms of bullying but warns that an improvement in the quality of the recording of incidents is needed.
2.6 The TUC believes that any discussion about violence against women, bullying and respect should include staff. TUC surveys regarding the experience of women workers and trade union representatives have led to the production of a guide for employers and trade unions reps on tackling domestic violence. A workplace policy on issues relating to violence against women and sexual harassment would provide the necessary underpinning to the creation of a safe environment in schools and colleges, where VAW is taken seriously as an issue.
2.7 Women working within the school and college workforce may experience violence in the workplace, as well as at home. Surveys by, and feedback from teacher union affiliates regularly find that women members of staff experience sexual harassment from pupils. A survey conducted by the NUT in 2006 found that 39% of teachers had encountered sexist language being directed by pupils to colleagues. 11% had reported that they had experienced sexual harassment themselves. Younger women experienced disproportionately higher levels of harassment.  The NASUWT's 'Safe to Teach?' survey reported that more than one in six (17%) women teachers had suffered from sexist abuse at school or college over a two year period. The survey also found that 67% of teachers had suffered some form of prejudice related bullying over the past two years. Of these incidents, 52% had been committed by pupils, 23% by line managers, 16% by colleagues and 2% by a governor. Those surveyed reported that 16% of these related to body image, 13% to sexism, 5% to homophobia, 6% to racism and 2% to disability. It is clear that these experiences contribute to the attitudes underlying VAW. These incidents were often not dealt with appropriately, with 45% of respondents who had reported the incidents saying that no appropriate action had followed. The NASUWT concludes that a school which failed to tackle effectively the bullying of its employees would find it more difficult to develop an effective and credible response to safeguarding pupils.
3.1How do social attitudes towards girls and women affect the problem of violence against women?
3.1 Violence against women is both a cause and a consequence of women's inequality and is the foundation for those social attitudes that legitimise violence against women and girls. Improving women's life chances and opportunities is central to the improvement in the confidence of women and girls which the consultation document refers to. Cultural assumptions about the value and nature of women's work and an equitable level of financial remuneration are closely related to deeply rooted views about the relationships between men and women. The TUC and its affiliates also believe that the widespread objectification of women's bodies within the media and assumptions about women's sexual availability is a contributory factor in VAW. The mainstreaming of the sex industry and pornography, the commodification of sex and the increasing sexualisation of young girls is of great concern.
3.2 Surveys conducted by EVAW in 2006 and by Amnesty International in 2005 found a sizable minority holding disturbing views that condoned the violent treatment of women and girls. These views are influenced by perceptions of women's emotional weakness, their social and political inequality, gender stereotyping and assumptions about male and female roles. Attitudes that justify VAW also intersect with views on race, disability and sexual orientation. Tackling these views and encouraging a significant change in our culture would be best supported by effective prevention work, raised awareness and appropriate support for women and girls affected by VAW.
3.3 Recognition that VAW is a public policy issue which affects the work of a whole range of government departments would also be a significant step forward. EVAW's 'Making the grade' reports have highlighted the fact that out that those countries that had adopted integrated plans of action on violence against women report benefits that include better inter-agency working, raised awareness of the issues, more effective legislation and policies and innovative practice. The TUC was involved in the work of both reports. Following the first survey into the work of Government departments in 2005, which found a lack of coherence and great variation from department to department, the 2006 'Making the Grade' survey examined progress made to date. The second survey revealed that while good progress had been made in some departments, particularly the CPS and Home Office, it became clear that a failure to grasp the concept of violence against women, unstructured work, lack of strategic indicators and shared goals across government continued to hamper work on domestic violence and violence against women. Many of the responses received from Government departments revealed a lack of awareness of how the work of that department could tackle VAW. The Gender Equality Duty (GED) also presented the opportunity for Government departments and other agencies to think seriously and practically about how gender based violence is a real barrier to achieving and promoting women's equality. The TUC welcomes the EHRC's intention that provision of VAW services is one of its acid tests for the implementation of the GED.
3.4 The TUC welcomes the explicit acknowledgement of the literally life-saving work of the women's groups and women's sector within the consultation document. The consultation goes on to ask how cultural beliefs which promote forced marriages, crimes committed in the name of 'honour' and FGM can be challenged. These are issues that have been raised, along with wider VAW issues, by groups working for ethnic minority women for decades. They have also been supporting women within these communities and challenging harmful cultural traditions long before there was widespread awareness of such issues. It is of great concern that the groups who most effectively challenge these attitudes and who provide the crucial specialist service provision for women in ethnic minority communities have been threatened by funding shortages. An intense focus on harmful cultural traditions has therefore not resulted in greater support for vulnerable women affected by them and has instead contributed to the 'othering' of black women who can be rendered invisible within discussions about VAW strategies except in the context of 'cultural backwardness' and debates surrounding community cohesion. The TUC believes that closure of service provision gaps experienced by certain groups, including BME women is critical.
4.1Are we doing enough to protect and support children affected by adult violence? Who's looking out for them and what do they need.
4.1 The TUC believes that an integrated children's workforce with an emphasis on safe reporting mechanisms would improve child protection and support. Appropriate support and training is essential for all staff that come into regular contact with children. However, it is important that roles are appropriately defined and understood. Teacher union affiliates see an important role for their members supporting children living with violence, including noticing physical signs and relevant changes in behaviour. They have argued that all staff who work with children should have access to basic child protection training that equips them to recognise and respond to child welfare concerns but that those with designated lead responsibility for child protection should receive training in inter-agency procedures. This would enable them to effectively work in partnership with other agencies. They have also emphasised the importance of schools not being expected to address violence in isolation and that this work is in fact best undertaken within a multi-agency context.
5.1How can we all better pick up on, and respond to, early signs of violence?
5.1 Ongoing efforts to identify, respond to and support those women experiencing violence are hampered by the varying responses that they continue to encounter. Women should feel able to speak openly about violence they are experiencing, feel that they will be believed and receive appropriate support and protection if they did so. The survey of local authority provision conducted by EVAW for 'Map of Gaps 2' found that only 11 out of 408 local authority services can claim to have a range and diversity of provision. Women should be able to access safe spaces where they can disclose information. Furthermore, specialist services are required to provide the support that women's diverse needs and situations might require. This is particularly true of vulnerable women for whom disclosure would mean increased risk. Again, Map of Gaps found that one in four local authorities have no specialised support at all. Just one in ten had a specialised service for ethnic minority women. Despite the fact that the majority of women do not report violence to the police, resources seem to be focused on the statutory sector, with 60% of new services opening in 2008 found within the statutory sector. EVAW also reports that a recent Women's Aid Federation of England survey noted that three-quarters of responding services were concerned about the impact of commissioning on their ability to provide the range of interventions aimed at meeting the needs of women. Beyond highlighting these serious concerns regarding the provision and sustainable funding of services, the TUC believes that training and support in identifying and responding appropriately to signs of violence to all frontline staff is essential in increasing consistency of response. Finally, a focus on preventing violence before, rather than after its occurrence will produce the best result of all for women and girls.
What kind of services should you expect to receive from the health service and/or social services if you were a victim of violence.
5.2 The TUC follows EVAW in calling for Health and Social Services to commission a diversity of services from organisations which have proved their ability to support women, both through their longevity and their use by women. These include help lines, refuges, advocacy, counselling and group work, with the understanding that some groups, such as BME women, LBT women and disabled women may have additional needs. The House of Commons Home Office Select Committee report on domestic violence, forced marriage and 'honour'-based violence noted that health professionals were often the first port of call for victims and that those affected by violence had long-term physical and mental health needs. Violence against women costs the NHS an estimated £1.2bn a year for physical injuries and £176m for mental health support. Despite this, EVAW found that the Department of Health had made no significant investment in specialised VAW services nor made reference to violence against women in its departmental strategic plans. Recognition of the importance of tackling VAW in implementing the Gender Equality Duty will also help better responses to women experiencing violence.
6.1How can central government, local government and other service providers best work together to promote better consistency and quality of provision in services for victims of violence against women across England?
6.1 Sustainable, long term, funding continues to be a big barrier in delivering adequate provision and delivery of support services for women experiencing violence. There is a critical need to reassess the commissioning arrangements for VAW services. A survey of Rape Crisis England and Wales centres indicated that almost a quarter (24.1%) faced closure this financial year and almost two-thirds (39.3%) face closure in 2009/10 because of a lack of funding. Members of the EVAW coalition have reported on the preference of local authorities to move to a 'one-size fits all' mode of service provision. Long standing women's groups who have built up expertise and trust with the communities they serve and who provide necessary specialist service provision are finding their funding being cut in preference for one provider to supply all services. In evidence to the Home Office Select Committee's Inquiry into Domestic Violence, Forced Marriage and 'Honour'-based violence, Women's Aid reported that 'there are examples in some areas where local authorities have commissioned generic providers with absolutely no track record in the field instead of local services that have been providing services for 30 years with the specialist trained staff.' Women's Aid also provided the Select Committee with five examples of where a contract for domestic violence services, previously provided by the local Women's Aid, had been awarded to generic housing associations under new commissioning processes.
6.2 Women's experience of domestic violence is informed by their ethnicity, age, sexual orientation and disability. Women from some ethnic minority communities may face particular difficulties in accessing services that are responsive to their concerns, and may find it harder to leave a violent situation if it means they also leave behind other forms of community support. This situation is exacerbated by the lack of long term secure funding for services supporting vulnerable women and girls. Specialist service providers, particularly those serving BME communities have felt increasing pressure in recent years. A recent report by Imkaan indicates that 8 services have been lost in London over the last year. EVAW reports that 12 specialised BME providers identified that they are currently under threat of a merger with a generic organisation. At least two organisations have been taken over by housing associations as part of the already identified shift away from independent community based services led by women's organisations. BME women, women on low incomes, trafficked children, disabled women, women who live in rural areas and trans people currently experience service gaps that compound the difficulties they face in receiving support. The TUC is also concerned at the lack of provision for people within same sex relationships experiencing violence within the home.
6.3 The Gender Equality Duty should assist central government, local government and service providers in promoting better consistency and quality of provision. The TUC is therefore concerned that the implications of the Duty for specialist provision and gender-specific initiatives are appearing to be interpreted in a manner that has been detrimental to VAW service provision. The necessity of providing specialist services aimed at specific, women-only groups, where appropriate, in fulfilling the provisions of the GED, needs to be emphasised.
6.4 The TUC also believes that the development and implementation of a strategic, cross-departmental approach to tackling violence against women is fundamental to enable national and local government to work effectively in tackling VAW and therefore welcomes the approach taken by this consultation paper. However, the most recent survey of the work of government departments by EVAW ('Making the Grade' 3) conducted in 2007 found that there were substantial gaps in understanding and commitment across government, with an average score of 2.18 out of 10. There is a concern that a meaningful cross-departmental approach will remain elusive as long as the lack of awareness of many government departments of their role remains. The TUC also believes that women need more, not less support during a recession and that the current economic climate should not be used as a means of postponing this vital work.
7.1How can we improve women's confidence that the criminal justice system is working to protect them?
7.1 The TUC welcomes recent initiatives by the Government, including use of measures to support vulnerable witnesses, and use of Specialist Domestic Violence Courts. However, a very low rate of conviction in rape and domestic violence cases, which are 5 % and 5.7% respectively, will not convince women that the criminal justice system will provide redress. The experience of going through the criminal justice system is also critical and there is a need to ensure that everyone the woman comes into contact with during this process treats her with respect and dignity, including first responders and investigative officers. A low conviction rate, too many women still encountering dismissive responses and the stressful nature of pursuing a case through the criminal justice process all contribute to a low rate of reporting and confidence.
8.1What would make your journey at night safer?
8.1 Safe public transport and public spaces is a very important issue for women, who are disproportionately likely to use public transport and travel on foot. Many women perceive public transport to be unsafe particularly at night, and women are four times as likely as men to be the victim of sexual assault, harassment or being exposed to, on public transport. This affects their employment and education opportunities. These concerns can become acute for those women living in rural areas who are confronted with a shortage of public transport. Trade union affiliates also continue to highlight issues of safety for women who work atypical hours and whose employment opportunities are affected by fears for their safety. In many cases, they may turn down work if they assess the time of night or travel route to be unsafe. The consultation document highlights the safety concerns of women when using car parks. USDAW reports that those of their members working in the private retail sector often worked in outlets built in isolated areas which were very difficult to access by public transport. While customer car parks tended to be well lit and staffed by security, staff car parks were often at the back of stores, hidden from view, poorly lit and unstaffed.
8.2 Closures and reductions in railway station's ticket offices and travel centres continues to be of ongoing concern to TUC affiliates. The TUC believes that properly equipped, maintained and staffed stations and other transport facilities are vital to providing a safe environment in which to travel. Given the important role that public transport can play in tackling VAW, the TUC was concerned that the Department for Transport failed to respond to EVAW's 'Making the Grade' report in 2007. The TUC also believes that other departments, such as the DCLG can influence the creation of public spaces that keep in mind women's safety concerns, as well as engage with women more in the planning and design of these spaces.
- A focus on preventing violence against women before, rather than after, its occurrence;
- Inclusion of tackling violence against women in the Government's Public Service Agreements;
- The development and implementation of a strategic, cross-departmental approach to tackling violence against women.
- Provision of long term, secure funding to support joined up services for vulnerable women and girls;
- Closure of service provision gaps experienced by certain groups, including BME women, women on low incomes, trafficked children, disabled women, women who live in rural areas and trans people;
- Service provision for those people in same sex relationships experiencing domestic violence;
- Use of the Gender Equality Duty to tackle violence against women, including an emphasis on the necessity of specialist services aimed at specific groups of women in fulfilling its provision;
- Awareness raising amongst employers of the impact of violence against women in the workplace and encouraging the provision of appropriate support, in consultation with trade unions.
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'Breaking the silence on Domestic Violence: A report on delegate surveys and workshops' TUC (2002)
 Silence is not always golden: tackling domestic violence NUT (2005) p5
 Silence is not always golden: tackling domestic violence' NUT (2005) p6
 Preventing Sexual Harassment and Bullying' NUT Policy Statement ( 2007) p6
 EVAW's information was obtained from Lovett, J. (2005) Briefing document on strategic approaches to addressing violence against women, London: Child & Woman Abuse Studies Unit
 Details of the survey questions and results, as well as statistics and case studies on violence against women can be found in 'Making the Grade 2006'which can be supplied upon request.
 Coy, M., Kelly, L., & Foord, J. 'Map of Gaps 2: The Postcode Lottery of Violence Against Women Support Services in Britain' EVAW (2009)p38
 ibid p 7
 Home Affairs Select Committee 'Domestic Violence, Forced Marriage and 'Honour' - Based Violence' Sixth Report of Session Volume 1 (2008) p49
 ibid p82
 Coy, M., Kelly, L., & Foord, J. 'Map of Gaps 2: The Postcode Lottery of Violence Against Women Support Services in Britain' EVAW (2009)P7
 ibid p7
 Home Affairs Select Committee 'Domestic Violence, Forced Marriage and 'Honour' - Based Violence' Sixth Report of Session Volume 1 (2008) p122
 'Making the Grade: the third annual independent analysis of UK Government initiatives on violence against women' EVAW (2007) p63
Issued: 18 June, 2009