Best Practices

LGBTQ Inclusive Policies & Practices

April 2019
Topics Allyship

Today’s corporations have repeatedly benefited by their actions to support and advance LGBTQ rights in the workplace. This report provides a wide array of information for creating a safe and inclusive work environment that values differences. Included are sample policies and practices, strategies and tips, and case study examples of what some companies are doing to address the needs of LGBTQ employees.

Today’s corporations have repeatedly benefited by their actions to support and advance LGBTQ rights in the workplace. This report provides a wide array of information for creating a safe and inclusive work environment that values differences. Included are sample policies and practices, strategies and tips, and case study examples of what some companies are doing to address the needs of LGBTQ employees.

The second section of the report has a more global lens. For multinational corporates that conduct business in jurisdictions that are not supportive of the rights of LGBTQ individuals—and in some cases penalize and persecute LGBT individuals—it can be challenging to extend nondiscrimination protections and offer equitable benefits to LGBTQ employees, while also adhering to local laws and customs. The report provides insight and case study examples highlighting how top companies are shifting culture and advancing LGBT equality around the world.

Creating a LGBTQ Inclusive Environment

Educate the Workforce. There is limited knowledge around transgender issues in the wider community, and what information is available is often incorrect or misunderstood. Take training back to basics. Explain everything simply with as few buzzwords or jargon as possible. Use personal stories to highlight how people deal with being transgender in society and how society reacts to them.

Publicize. Make transgender awareness as ‘loud and visible’ as possible within the organization. Get senior leaders to actively and visibly support events. Provide awareness during team-building events, in social media communications, and
bring in external speakers to talk to the issue. The more people hear, talk and participate in transgender awareness and education, the more they will understand challenges facing the community, and the sooner it will become normalized.

Make it Safe. Don’t constrain conversations or questions by putting rules in place on what people can ask, what words they can and can’t use, and what they can and can’t say. Let the conversation be open and honest; make people attending feel safe as well as the presenters. Provide support to transgender employees through workshops, confidential helplines, and develop practical transition guidelines for managers, staff and transgender individuals.

Be Visible. Be Open. PRIDE buttons and flags signal support. So do “I’ll go with you” buttons that show that you will walk with a transgender person to the restroom. Be familiar with terminology for LGBT and neuro diverse communities. Understand how to support colleagues coming out at work: Ask “How can I help you?” Don’t assume that a person is out to everyone, whether about their sexuality, gender, or mental illness.

Ask Questions and Find Common Ground. For example, Have you ever known someone who was gay? Transgender? Autistic? Bipolar? Questions can help coworkers with different backgrounds, experiences, and needs find common
ground. For example: Did you grow up in the same area? Do you both have children? Do you do a similar kind of work?

Gender Transition Guidelines

Guidelines should include important information regarding:
• Who in the business is charged with helping a transitioning employee manage his/her workplace transition
• What a transitioning employee can expect from management
• What management’s expectations are for staff, transitioning employees, and any existing LGBTQ employee group in facilitating a successful workplace transition
• What the general procedure is for implementing transition related workplace changes, such as adjusting personnel and administrative records, as well as a communication plan for coworkers and clients
• Answers to frequently asked questions about dress codes and restroom use
• How to deal with employees (or customers) with religious or other objections

BP: Inclusive Training and Guidance

BP’s Pride BRG chapter in the UK established the Transgender Working Group to develop an educational framework and training program to increase awareness and ally support for transgender employees. The effort is part of the company’s ‘safe space’ initiative to create an inclusive and respectful working environment for transgender employees and to provide all employees with tools to help them become an active ally.

The coursework developed by the Working Group is presented on a monthly basis through a mix of in-person and virtual instruction. The training capitalizes on the recognition that personal stories are a powerful way of getting a message across. Each of the four modules highlights the real-life perspectives and experiences of a transgender employee with the goal of building understanding and dispelling stereotypes and misconceptions. The story-telling aspect allows for greater personal connection and teaches participants behaviors they can adopt to become an ally and actions they can take to defuse bias and microaggressions.

In the year since its launch, 450 individuals at BP have participated in the training initiative. Throughout the year, information related to the effort was widely communicated across internal communication channels and through social media to increase awareness and exposure among BP employees globally. Information about the coursework was featured on the front page of the company’s intranet site, which is shared with more than 75,000 BP employees.

Building on the success of the training initiative, the Working Group developed comprehensive guidelines to help managers, work teams and peers understand the transition process and become allies to employees who are transitioning. The guidance document outlines key language and terminology, provides points of contact, and includes information about BP’s policies, practices and expectations. It details the responsibilities of the person transitioning, as well as their line manager, and offers practical tips for developing an action plan for transitioning in the workplace.

Safe Space for Open Conversation

GLEAM is the lesbian, gay, bisexual, and transgender (LGBT+) employee resource group at Microsoft. GLEAM members interact through programs such as: Ignite talks, lunches, cross-corporate LGBT+ networking, sporting events, cultural activities, discussions with community leaders about gender and sexuality, volunteering, and fundraising for local LGBT+ organizations.

Coca-Cola has been on the forefront of ensuring equality for its LGBTQ associates. In 2011, Coca-Cola began offering transgender-inclusive health insurance coverage and in 2015 it began assisting with the costs of taxes imposed on eligible U.S. employees whose same-sex spouse or partner was enrolled in health benefits and who lived in states that did not recognize same-sex marriage.

Accenture offers LGBTQ employees professional development, inclusive policies, recruitment and retention guidelines, equal benefits as well as a global Ally program with more than 24,000 members.

EY’s LGBTQ employee group UNITY offers equality benefits such as spousal equivalent domestic partner recognition, gender transition coverage, and tax gross-up on domestic partner benefits.

GuideWell: Safe Space for Open Conversation

In 2016, GuideWell rolled out a new culture focused on three core principles: Be well, Work well, Guide well. The company’s leadership recognized that to keep with the newly instituted culture of inclusion and respect, they needed to create a safe space for employees to talk openly and share perspectives about uncomfortable and difficult to discuss topics. With that objective in mind, a series
of discussion forums were planned to facilitate ‘courageous conversations’ around topics including race, religion, and sexual orientation. One of the forums is focused on Rules of Engagement with the Transgender Community.

Although GuideWell’s executives, including the CEO, are very involved in the forums, serving as sponsors, facilitators and panelists, employee community groups gather input from employees around the topics to be addressed, lead the discussions, and serve as panel members. Sessions are open to all employees, with 50-75 employees participating in-person and approximately the same number joining virtually from company locations across the country.

Feedback from session participants has been extremely positive. Employees felt they were heard, their concerns were validated, and specific plans to continue to move the conversation forward were identified.

In a survey following the most recent forum, 96% of respondents said they are likely to attend another discussion forum; 91% agreed that they can be transparent with their thoughts, feelings and ideas; 92% said that their business area leader is open to diverse opinions and ideas; 96% agreed that the company’s values of respect, integrity, imagination, courage and excellence guide what the company says and does, and 96% believe they can be their best self at work.

Key Actions For Inclusive Policies

Culture varies greatly across geography. Within a country, one may find urban and progressive metropolitan areas alongside rural and conservative areas (e.g. Turkey and mainland China).

Many emerging market countries (such as Indonesia, India and South Africa) are highly diverse, with many different languages and cultural traditions. As a result, what might work in one office might not work in another office in the same country.

Emerging markets are undergoing significant cultural shifts driven by rapid economic growth, migration, the spread of traditional and social media, and globalization. In South Korea, Taiwan and most of Latin America, attitudes toward LGBT+ people have changed for the better very rapidly over the past decade—especially among younger generations.

In addition, globalization is driving cultural backlashes as people reject the idea of imposing specific cultural values (often Western or “Anglo” values) on others. Across much of Africa and Southeast Asia, LGBT+ initiatives often are perceived as Western and can be construed as part of a “neo-colonial” agenda. Such negative associations can be a detriment to local D&I initiatives.

Do the company’s global policies prohibit discrimination and harassment based on sexual orientation and gender identity?

Do the company’s mobility policies or guidelines set out:
• That LGBTQ employees will not suffer a career detriment if they decline a post?
• That LGBTQ employees and families receive active support with immigration considerations?
• That international assignments should not have a negative impact on the healthcare available to the LGBTQ employee?
• That family benefits will apply equally regardless of gender?

Are the company’s mobility staff trained to support mobile LBGTQ staff?

Do you understand what factors can influence the experiences of LGBT staff working internationally?

Do you collect and keep up to date with legal and non-legal country information relevant to LGBT people?

Do you carry out risk assessments and develop risk management plans that include LGBT issues?

Policy Considerations


The level of healthcare available differs greatly around the world. Specialists who provide LGBT-inclusive healthcare may not be available in all locations. Overseas assignments should not have a detrimental effect on the healthcare available to assignees. This needs to be reflected in mobility policies or guidelines. Organizations can work with assignees to prepare them for the level of care available. This involves creating an action plan in case their needs can’t be met locally. For example, the organization could cover pre-travel assessment and planning, access to a global medical assistance service and regular visits to the sending country. LGBT staff may also need health insurance that enables them to be flown back home or to a third country for treatment in emergencies.

Family Benefits

Many organizations offer benefits associated with the assignment, such as language and cultural awareness training. Where this is offered to family members, it should be explicitly LGBT-inclusive. Offering these benefits to unmarried and unregistered couples further ensures they apply to couples even if marriage or civil partnerships are not available to them.

In some countries, different-sex couples are eligible for tax breaks unavailable to same-sex couples. Organizations can compensate for this by making up the difference in the employee’s salary.

Diverse Families

International assignments not only affect your employees but may also affect their families. This is especially true for longer-term assignments. It is important to remember that LGBT families, like all families, are diverse. For instance, it may be the case that your employee is not LGBT but their partner or child is. In other cases, the legal parental relationships to a child might not be as clear as in non- LGBT families. Mobility policies or guidelines should acknowledge that all families,
including LGBT families, are diverse and can expect equal and tailored support. They should also state that the organization offers equal support, no matter whether the employee, their partner or their children identify as LGBT.

Immigration considerations

International assignments pose immigration considerations, such as the need for visas, for every mobile employee. For LGBT employees and or family members there may be additional barriers. The best mobility policies or guidelines
therefore state that tailored immigration support will be provided on an individual basis. They also explicitly state that such support is inclusive of sexual orientation and gender identity considerations.

Where relocation support is offered to family members, this should be clearly LGBT inclusive. Where dependent visas are not available to same-sex couples, the best organizations commit to finding alternative ways of relocation, if possible. The very best policies and guidelines state that additional travel expenses will be covered where family relocation isn’t possible.

In committing to immigration support, policies or guidelines also need to be clear that there may be certain factors beyond the organization’s control.

Rejecting Overseas Assignments

Mobility policies or guidelines should state that employees’ careers won’t suffer if they decline a posting because of their sexual orientation and gender identity. Other career development opportunities should be sought where an employee rejects an assignment on these grounds. The best policies or guidelines have the same approach for all identity characteristics, for example, disability or ethnicity.
In some cases, it may be possible to offer an alternative means of accepting the assignment, such as working remotely.

In other cases, the organization can offer career development opportunities of equivalent merit. Some employees are not comfortable with other people knowing their reason for declining an assignment. It is important for managers to ask employees if that is the case and to respect their decision. Where the declined offer poses difficulties to a team, managers should firmly but sensitively handle any negative reactions from colleagues.

Set Policy Globally, Customize Implementation Locally

While starting with a global LGBT vision and policy is important, implementation on the ground must be calibrated to local conditions:
• Use alternative language and historical references that are relevant to the local culture. The concept of a “third gender” has currency in South Asia, for instance. In 2014, India’s Supreme Court legalized this gender and mandated affirmative action measures.
• In geographies where diversity is perceived as a less relevant, or foreign, topic, alternative approaches emphasizing respect of all people, inclusion or authenticity may work. Pose questions such as: “what is it like to not be able to discuss your partner or your weekend?” and “what would it be like to have to lie about yourself at work?”
• In many Asian countries (such as Japan and South Korea), discussing personal issues of any kind in the workplace is taboo and “don’t ask, don’t tell” cultures prevail. Often, an effective approach in Asia is to include LGBT in to the broader D&I agenda alongside gender, work-style/flexibility, culture/nationality, generations and other diversity aspects.
• In territories where direct references to sexual orientation and gender identity in policy, codes of conduct or communications are not advised, it is possible to emphasize universal principles such as tolerance, equality and fairness, and the fact that harassment and discrimination are not permitted.

For all of these situations, it’s imperative to obtain the guidance of local LGBT personnel to build support for initiatives and identify the right language, tone and approach.

Moving From Policy to Practice

Many companies aspire to being “global,” with a consistent corporate culture reflected across all geographies. In reality, most are multinational companies, e.g., a single brand operating in various local markets. Consequently, corporate culture often varies greatly across geographies, and the same is true for LGBT advancement.

Headquarters can talk forcefully about equality and inclusion, but the pace at which regional business units implement global LGBT policy and initiatives depends on a number of variables.

One factor is the level of autonomy business units enjoy. Some business forums and practices, such as partnership networks, franchises and organizations that rely heavily on outsourcing, can militate against top-down efforts to implement global LGBT policies.

Another driver is the priorities of local leaders and the perceived risks they are willing to take on behalf of LGBT personnel. A local manager who has positive feelings toward LGBT people, or who aspires to a global leadership role, may be personally motivated to align themselves with and promote global LGBT policy and practice.

In emerging markets, where managing growth can be all-consuming, LGBT inclusion may drop down on the list of management priorities. Change often emerges spontaneously from the grassroots. Out and enterprising LGBT staff or HR personnel may take the initiative and form a local employee resource group (ERG) and network, call out perceived bias or engage in reverse mentoring.

The first step is to look beyond the corporate hub and gain an understanding of the reality on the ground.

LGBTQ Allies and Advocates

Individuals can be engaged to advance LGBT as inclusive leaders, allies, sponsors and role models. Inclusive and out leaders and role models can be particularly powerful in many Asian cultures, given the high esteem they invest in seniority. For example, by not tolerating insensitive remarks about the LGBT community and other actions that affect the productivity and working conditions of LGBT employees.

Also, it is important for global leaders to engage local leadership in making it safe for local LGBT and advocate employees to feel empowered as part of the global LGBT community as well as for the local teams to create a local chapter.

Even in places where open discussion and advocacy of equality is not possible, subtle messaging and demonstrations of tolerance and inclusivity can be compelling.

At times, it is important to create room for people to say “no” to becoming highly visible and vocal allies, as long as they are leading inclusively on their teams and creating an inclusive environment for all.

Many cultures around the world, especially those in emerging markets, put a high value on and invest in, trusted personal relationships and, as a result, tend to rely less on formal institutions, such as the law, to enable or drive change. As a result, leaders, allies, sponsors and role models can encourage change through dialogue and relationship building—over dinner, or while collaborating on a project.

If your company doesn’t have any out senior executives, it’s a good time to ask why.

Pre-Departure Support & Training

LGBT-inclusive pre-departure support allows LGBT staff and employees with LGBT family members to make an informed decision about international assignments. It also ensures non-LGBT staff understand how their actions may affect their LGBT colleagues.
• Many organizations compile country information for staff going on international assignments. This should include information on the in-country situation and risk factors for LGBT people.
• It is also vital to provide the same risk information for non-LGBT staff, as they may have dependents who are LGBT. In addition, non-LGBT staff may need to adjust their behavior during the assignment. For example, they need to know the risk of inadvertently disclosing a colleague’s LGBT identity when traveling together. For example, training can be provided on whether it is safe to talk openly about someone’s sexual orientation or gender identity while traveling.
• The best organizations provide information about their own LGBT diversity and inclusion initiatives taking place globally and in the assignment country. This can include information on anti-discrimination and harassment policies, LGBT-specific training, events, leadership engagement, allies programs and LGBT employee networks.
• Many companies collate insights from LGBT staff in assignment countries. This gives candidates a more detailed account of what the experience has been for others abroad. However, it is important to acknowledge that individual experiences can differ greatly. When providing real-life insights, safety considerations should be of utmost importance. Where it is dangerous for an employee to be out, real-life insights can be anonymized.

Leverage Social Media as a Support Mechanism

Strong communications channels across the enterprise are important for advancing LGBT diversity globally. For people in locations without local resources, having access to global resources—conference calls, webinars and social media—is critical.

Social media, such as Facebook, Twitter and Yammer are good for sharing news about events such as pride rallies. Barclays has a One Million Stories campaign, where staff from around the world can go online and talk about themselves and their situation. Whether in the Philippines, Brazil or China, social media is the most effective channel for engaging younger cohorts.

LGBT-themed webcasts and video conferences that feature top-level executives can set an example for regional managers to model. News from the headquarters or a webcast involving a global executive, can set an example for offices in China, for example.

Informal and confidential channels—such as hotlines and ally networks—are valuable. Baker & McKenzie’s Listening Ear program makes a team of individuals visible and available for confidential consultations concerning the firm and its culture.

Global D&I managers should give thought to their information distribution policy. Some companies do not publish LGBT news on global platforms and restrict distribution to countries that are considered “safe.” Other companies, such as Barclays, push their information out globally but calibrate the message and the language locally.

Key Resource: Out Leadership

Out Leadership, provides companies with primers on how to operate in countries that criminalize homosexuality, including talking points for top executives to raise with local officials and ratings on how the law is applied in specific nations.

In India, for instance, consensual homosexual acts are illegal and can bring jail terms. Still, Out Leadership advises corporate clients that the government there doesn’t actively prosecute LGBT individuals. While such intelligence can provide a measure of comfort to companies worried about worker safety, there’s a profit motive as well, because such knowledge also indicates “there is low risk of an international firm losing LGBT clients because they do business in India,” the group said.

The group reports that what most companies do to protect their LGBT employees in the most difficult locations is to simply not send them. And when they do go, employees tend to just avoid mentioning their sexual identity.

“Policy does not equal culture. While more than 90% of firms have articulated inclusive policies, more than 40% of LGBT people are still not out at work. Out leaders can make all the difference.” – Todd Sears, Principal, Out Leadership

Global Case Studies

IBM: Extending Inclusion Globally

Running an LGBT network in China poses unique challenges. The idiosyncrasies of Asian culture in general and Chinese culture in particular come into play and LGBT employees may find it difficult to be themselves when subjected to societal and familial pressures. A lot of times, LGBT employees are reluctant to come out in the workplace due to concerns that their family and friends may find out.

IBM has kept these concerns at bay by taking stringent measures to protect the privacy of their employees. For example, employees who choose to disclose their sexual orientation in the “About You” Diversity & Inclusion Profile are assured of
their privacy. The information is used in developing learning and developmental opportunities, networking, mentorship, leadership seminars, and other similar diversity related initiatives, but it is important to note that direct managers cannot
access this information. Aside from data encryption and other security measures, this information is actually managed by a single individual globally. All email communications to groups blind copied as an extra measure.

Because securing and maintaining the buy in of key stakeholders is a common pitfall in other organizations, IBM continuously engages senior leaders and management to make sure their diversity strategies are consistently applied. For
example, Lily Low, the CFO and LGBT Ambassador for IBM – China, recently released a video declaring her support and commitment to the LGBT community. IBM ensures that its middle management, who are critical to driving diversity
initiatives, are fully engaged through worldwide training programs. Reverse mentoring programs for managers and LGBT network members are designed to raise awareness and help middle managers tackle LGBT related issues and challenges.

EY Leaders Send Message

EY opts to have a high-level executive talk about LGBT issues in some Asian countries because it carries more weight with employees and clients. The company also makes the case that diversity helps performance not only from a talent perspective but in a company’s branding in the marketplace. In Japan, one of the firm’s key leaders is a gay man who brought his husband to the post.

EY offers the same benefits to same-sex domestic partners that are given heterosexual couples working abroad, including help obtaining a visa for a partner. EY tries to accommodate workers who decline a move to inhospitable places, or those who get there and then ask to leave.

Workers who do take jobs in countries with severe anti-homosexuality laws tend to hide their sexual identity, and not surprisingly, same-sex partners are usually unable to get a visa to those countries. Such locales can also be hard for unmarried heterosexual couples.

EY makes provisions in its global mobility policy for dependents—spouses, partners and children—to accompany employees on international assignments. The policy explicitly defines a dependent spouse or partner as a ‘legally recognized spouse or partner (including same-sex and co-habitation relationships as defined under home country laws), significant other (including same-sex partners) or fiancé(e)’.

JPMCs: Engaging Allies in India

JPMC’s PRIDE India Allies chapter helps foster local community awareness around the firm’s inclusive agenda. Goals of the chapter are to nurture and expand the active community; build internal share and support groups; create awareness within the broader firm; and provide Pride participants with a strong platform to share and connect.

The company has local LGBT Employee Resource Group (or ERG) chapters in 15 countries. One of the international chapters reached out to company leadership asking them to call on the local legislature to pass anti-discrimination legislation. JPMC leadership considered many factors, including public support for the measure in the country, the impact on our employees there and the political landscape. Ultimately, the company did take action and spoke out to the local legislature.

Citi: Developing Resources

Citi has a dedicated website to inform mobile staff and their families about assignment destinations. All country pages contain information on LGBT issues. This includes information on LGBT-specific laws, for instance whether same-sex partnerships are recognised and the visa options available to same-sex partners.

It also covers non-legal information, such as societal levels of acceptance, crime rates against the LGBT community and information on LGBT groups and events.

The LGBT-specific information is incorporated throughout the website to make sure it is available to all employees reading about a destination. Mobile staff are also informed about Citi’s staff networks in assignment countries, including LGBT staff network chapters.

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