POL_W2 Welsh Language Policy: Awarding Grants
Version: V1
Active Date: 24/7/24
Document Owner: Democratic Services Manager
Does this Policy Relate to Me: All Officers who are responsible for awarding grant funding.
Quick Reference – Key Policy Messages:
- The Pembrokeshire Coast National Park Authority is fully committed to the principle of allowing Welsh speakers to use their language in all aspects of their lives and recognises its responsibility to facilitate and promote this use.
- This policy is to assist officers to ensure that Welsh Language Standards considerations are an integrated element of the grant process across the Authority.
This policy is also available in Welsh
Contents
- Policy Statement
- Aim of Policy
- Scope of Policy
- Definitions
- Legislation
- The grant awarding process: How Welsh language considerations can be integrated
- Information to support the decision to award the grant
- Assessing grant applications
- Awarding the grant
- Taking and implementing grant decision
- Monitoring the use of the grant
- How grant decisions can affect the Welsh language
- Standard conditions that could be imposed for all grants
- Monitoring and Assurance
1. Policy Statement
1.1 The Pembrokeshire Coast National Park Authority is fully committed to the principle of allowing Welsh speakers to use their language in all aspects of their lives and recognises its responsibility to facilitate and promote this use. This policy sets out the Authority’s requirements when funding individuals / organisations.
2. Aim of Policy
2.1 This Policy has been developed in order to provide guidance to Officers on how to comply with the requirements of the Welsh Language Standards when advertising and awarding grants on behalf of the NPA. Awarding grants has the potential to have far-reaching effects on the Welsh language, whether directly or indirectly; many of these grants have a social and economic impact which in turn has an impact on the Welsh language. The Welsh Language Standards requires consideration of what effect the award of the grant would have on the:
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- opportunities for persons to use Welsh in the context of the activity
- not treating Welsh less favourably than English in the activity
2.2 The aim of this policy is therefore to assist officers to ensure that Welsh Language Standards considerations are an integrated element of the grant process across the Authority in support of its work to promote the Welsh language.
3. Scope of Policy
3.1 The principles of this policy apply regardless of the size of the grant. Therefore, a process will be necessary to identify what language requirements will be needed for the relevant activity, and to set conditions for the awarding of the grant. For example, a small grant could be awarded for organising a small community event; and in such a case, it would be appropriate to set conditions that signs and publicity material for the event should be bilingual. As with the larger grants, it is important to make clear to grant applicants what is expected of them as organisations in relation to the use of Welsh. Where appropriate, support should be given to grant recipients so that they can comply with the principles set out in this Policy.
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- This policy will apply when the Authority awards grants in which the Authority itself provides the funds.
- This policy will apply if the Authority awards grants on behalf of another body, the Welsh Government or any other body falling within the scope of the Welsh Language (Wales) Measure 2011), and the specific terms and conditions of the grant include considerations in relation to the Welsh language.
- The policy will not apply if the Authority is not responsible for setting the policy and its direction, and the terms and conditions for those external funds cannot be changed. However, in this situation all other relevant Welsh Language Standards must be adhered to, namely publication of Welsh versions of the guidance and consultation documents, application forms, publicity material etc.
4. Definitions
4.1 In the Code of Practice Welsh Language Standards (No. 1) Regulations 2015, the Welsh Language Commissioner explains what constitutes a ‘grant’:
“A grant is usually a permanent transfer of money to a person, that does not need to be repaid nor returned. The term includes any financial support which a body provides to a person for a specific project or purpose. A grant will usually only cover part of the total costs. Grants are usually used in accordance with specific terms and conditions. The term may include financial support or benefit but does not include a sum of money that is given to a person through a procurement process, for example services that are commissioned.”
5. Legislation
5.1 Legislation relevant to this policy includes:
5.2 The Welsh Language (Wales) Measure 2011
The Measure sets out a legal framework which imposes a duty on all local authorities and National Park Authorities in Wales, to comply with the Standards relating to the Welsh language.
5.3 Welsh Language Standard 94 (Policy Making Standard)
You must produce and publish a policy on awarding grants (or, where appropriate, amend an existing policy) which requires you to take the following matters into account when you make decisions in relation to the awarding of a grant:
(a) what effects, if any (and whether positive or negative), the awarding of a grant would have on:
(i) opportunities for persons to use the Welsh language, and
(ii) treating the Welsh language no less favourably than the English language;(b) how the decision could be taken or implemented (for example, by imposing conditions of grant) so that it would have positive effects, or increased positive effects, on:
(i) opportunities for persons to use the Welsh language, and
(ii) treating the Welsh language no less favourably than the English language;(c) how the decision could be taken or implemented (for example, by imposing conditions of grant) so that it would not have adverse effects, or so that it would have decreased adverse effects on:
(i) opportunities for persons to use the Welsh language, and
(ii) treating the Welsh language no less favourably than the English language;(ch) whether you need to ask the applicant for any additional information in order to assist you in assessing the effects of awarding a grant on:
(i) opportunities for persons to use the Welsh language, and
(ii) treating the Welsh language no less favourably than the English language.
5.4 Welsh Language Standards 71, 72, 72A, 74 and 75 (Service Delivery Standards)
71 Any documents that you publish which relate to applications for a grant, must be published in Welsh, and you must not treat a Welsh language version of such documents less favourably than an English language version.
72 When you invite applications for a grant, you must state in the invitation that applications may be submitted in Welsh and that any application submitted in Welsh will be treated no less favourably than an application submitted in English.
72A You must not treat applications for a grant submitted in Welsh less favourably than applications submitted in English (including, amongst other matters, in relation to the closing date for receiving applications and in relation to the time-scale for informing applicants of decisions).
74 If you receive an application for a grant in Welsh and it is necessary to interview the applicant as part of your assessment of the application you must – (a) offer to provide a translation service from Welsh to English to enable the applicant to use the Welsh language at the interview, and (b) if the applicant wishes to use the Welsh language at the interview, provide a simultaneous translation service for that purpose (unless you conduct the interview in Welsh without a translation service)
75 When you inform an applicant of your decision in relation to an application for a grant, you must do so in Welsh if the application was submitted in Welsh.
6. The grant awarding process: How Welsh language considerations can be integrated
6.1 All information materials regarding the grant must be available in Welsh and will be published at the same time as the English version, including any guidance documents, assessment frameworks and terms and conditions. The information will also indicate that the Authority will consider the effects on the Welsh language when awarding the grant.
6.2 The following disclaimer should be placed when advertising the grant:
Caniateir cyflwyno ffurflen gais yn Gymraeg ac ni fydd unrhyw gais a gyflwynir yn Gymraeg yn cael ei thrin yn llai ffafriol na chais a gyflwynir yn Saesneg.
An application form may be submitted in Welsh; any application submitted in Welsh will not be treated less favourably than an application submitted in English.
6.3 If information materials need to be published in English and Welsh separately, the following sentence should be placed on the front page of the English document(s):
Mae’r ddogfen hon hefyd ar gael yn Gymraeg.
This document is also available in Welsh.
7. Information to support the decision to award the grant
7.1 The standard requires that consideration should be given to what additional information is needed in order needed to consider the effects on the Welsh language. Applicants can be asked for this information at any point in the decision consideration process. For example:
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- ask standard questions about the effects on Welsh as part of the application form
- request additional information from applicants following receipt of applications
- ask questions about the effects on the Welsh language in any interviews that are conducted.
7.2 Below are examples of the questions grant applicants can be asked.
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- Have you considered what the effects of the activity will be on the Welsh language? What will be the positive and/or negative effects?
- How will you actively increase positive effects on the Welsh language, and decrease the negative impacts?
- Do you have enough staff or volunteers to enable people to use Welsh?
- Have you arranged for any materials to be available in Welsh?
- Have you included any additional costs for Welsh language provision in your budgets e.g. translation costs?
- How will you ensure the quality of your Welsh language provision?
- What previous experience have you had of undertaking an activity that has positive effects, and does not have negative effects, on the Welsh language?
- Do you have any data that shows how your previous activities have affected the Welsh language?
8. Assessing grant applications
8.1 In order to consider the impact(s) on the Welsh language it is advisable to use the Template available in Appendix 2, or the following questions about Welsh can be added to the existing form for considering grant applications:
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- what will be the effects of awarding the grant on the Welsh language, and whether they are positive or negative?
- how can the decision be made or implemented in order to increase positive effects and decrease adverse effects?
- whether any additional information is required in order to take account of the effects on the Welsh language?
9. Awarding the grant
9.1 The effects on the Welsh language should be taken into account when making the final decision, e.g.as one of the criteria for the grant, or as part of a scoring system. The materials for recording the decision should indicate:
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- what consideration has been given to the Welsh language?
- How has this affected the decision?
9.2 The Terms and Conditions for the grant should clearly set out the expectations for the Welsh language, see Section 13: Standard conditions that could be imposed for all grants
10. Taking and implementing grant decision
10.1 To ensure that the decision increases the positive effects on the Welsh language, it is possible to achieve the goal in 2 methods (both can be done – it does not have to be one or the other).
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- taking the decision – awarding grants to applications that appear more likely to increase the positive impacts on the Welsh language, and reduce the negative impacts
- implement the decision– take steps to ensure that grant recipients operate in specific ways in order to increase the positive effects and reduce the negative effects.
10.2 It is not expected that the effects on the Welsh language will be the main, or only, factor taken into considered in deciding who will receive each grant. It is likely that there are a number of criteria against which applications will be measured, which relate to matters such as the extent to which the application fits the objectives of the grant, and the extent to which the application provides assurance that the funding will be dealt with appropriately.
10.3 The effects on the Welsh language should be added as one of the criteria to use when taking the decision to award the grant. If a scoring system is used for deciding which applications to award grant on, the effects on the Welsh language can be added as one part of that scoring system, giving applications a score based on consideration of their effects on the Welsh language. However, it will be up to the Awarding Officer to decide the weighting attributed to the effects on the Welsh language as part of such a system. It is important to keep a proper record of how consideration of the effects on the Welsh language has influenced the final decision in awarding the grant.
10.4 The grant can be awarded subject to specific steps being taken to ensure that the positive effects on the Welsh language are increased, and negative effects are decreased. It will be necessary to ensure that these conditions, and the consequences of failing to abide by them, are absolutely clear to grant recipients. The requirements should be listed in terms and conditions, or an award letter. (See: Section 13).
10.5 Note: One effective method of ensuring that businesses or charities develop their use of Welsh is to require them to develop a Welsh Language Offer, which is facilitated by the Welsh Language Commissioner. The system creates a plan for a level of Welsh language provision based on a questionnaire and gives businesses and charities the opportunity to set targets, to increase their Welsh language provision, supported by the Welsh Language Commissioner’s Promotion and Facilitation Officers. Cynnig Cymraeg (comisiynyddygymraeg.cymru)
11. Monitoring the use of the grant
11.1 Requirements to report back on the use of the grant to include reporting on:
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- what action the recipient took to increase positive effects and decrease negative effects on the Welsh language
- what positive and negative effects the grant had on the Welsh language
12. How grant decisions can affect the Welsh language
12.1 When making a decision on awarding a grant, the Welsh Language Standard states that the Authority must consider the effects on the Welsh language. The template in Appendix 2 offers a method of recording the effects
12.2 Two types of effects on the Welsh language need to be identified. Those effects reflect the two main objectives of the standards:
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- ensuring opportunities for persons to use the Welsh Language
- treating Welsh language, no less favourably than the English language.
12.3 In the Code of Practice to the Welsh Language Standards (No. 1) Regulations 2015, the Welsh Language Commissioner explains the meaning of ‘treating Welsh language no less favourably than the English language’ as follows:
“The practical meaning of ‘varies from situation to situation. But in general, it’s about not putting anyone at a disadvantage if they want to use Welsh, and ensuring that Welsh is at least as prominent, standard and accessible as English at all times.”
12.4 Once potential effects have been identified, it will be necessary to identify whether they are positive or negative:
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- positive effects are those that mean that there is an increase in the use of Welsh language, that the Welsh language is more visible, or that there are no additional barriers to the using Welsh, with outcomes that are at least as favourable
- negative effects are those that mean that there are fewer opportunities to use Welsh, the Welsh language is less visible, or that people who wish to use Welsh face more barriers or less favourable outcomes than people who use English.
12.5 Some questions that can be asked in order to identify the potential effects of grant making decisions on the Welsh language are:
12.6 Direct effects:
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- Will it be possible to use Welsh in public elements of the activity, and when communicating with the organisers?
- Will Welsh language be used in promotion and advertising of the activity?
- Will materials produced as a result of the activity be available in Welsh?
- Will Welsh be at least as prominent as English language in terms of materials, signage, logos, audio announcements etc associated with the activity?
- Will the activity have an effect on people’s understanding and awareness of issues relating to Welsh language?
12.7 Indirect effects:
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- Will the activity have an effect on the sustainability of communities where it is important to see growth or stability in the number of Welsh speakers and use of Welsh, for example as a result of an effect on the economy, planning, education or social opportunities? Will the activity have an effect on the number of children receiving a Welsh – medium education?
- Will the activity lead to the creation of employment opportunities for Welsh speakers?
- Will the activity lead to people being able to use Welsh at work?
- Will the activity lead to enabling and motivating people to use Welsh in the community or in the family?
13. Standard conditions that could be imposed for all grants
13.1 Examples of conditions that could be imposed on grant recipients, depending on the individual grant situation are provided below:
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- Offering specific services in Welsh, e.g: welcoming people, enabling the use of Welsh on the phone, audio announcements, correspondence in Welsh, offering a course in Welsh
- Publishing materials in Welsh, e.g: the project’s website, documents, signage, or creative output from the project
- Targeting Welsh speakers in promoting and advertising activity
- Ensure that activity takes place out in geographical locations that support the use of Welsh
- Host the activity in Welsh/ bilingually
- Developing and adhering to the Welsh language Offer Scheme [businesses and charities]. A scheme facilitated by the Welsh Language Commissioner.
- Complying with Welsh language standards or schemes [organisations under the relevant duties]
- Ensuring a suitable human resource capacity or budget is available to enable Welsh language provision
- Provide specific data or evidence on the effects of the grant on the Welsh language (see below)
14. Monitoring and Assurance
14.1 Grant recipients may be asked to report on how they have used the grant or how they have adhered to the terms and conditions of the grant. Information about the effects on the Welsh language could be asked as part of this. Examples of data or evidence that could be requested are.
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- Number of materials produced in Welsh / copies of materials
- Number of staff or volunteers who could offer a Welsh language service
- Number of Welsh speakers who took part in an activity
- Economic impact of activity in a particular area
- Number of jobs created as a result of the grant
- Areas where activities took place
- Feedback from users regarding the use of Welsh
14.2 A record should be kept of the total number of grants distributed, along with recording:
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- Number and % of applicants that have submitted their applications in Welsh, and how many have applied to conduct the interview for a grant in Welsh, as part of the assessment of the application.
- Number of organisations that have further developed their use of Welsh as part of the conditions to receive a community grant
14.3 A report on this data will be required as part of the Welsh Language Standards Annual Report
Appendix 1: Awarding Grant Checklist
If you manage a grant process on behalf of Pembrokeshire Coast National Park Authority, adhering to this checklist will ensure that you comply with the requirements of the Welsh Language Standards. Ensuring compliance will reduce the possibility of any complaint, appeals or investigations by the Welsh Commissar and the various costs associated with it.
Step: All information about the grant is available in Welsh and will be published at the same time as the English version, including any guidance documents, assessment frameworks and terms and conditions.
In action?
Step: The advertising documents inviting applicants to apply for the grant include the active offer:
Caniateir cyflwyno ffurflen gais yn Gymraeg ac ni fydd unrhyw gais a gyflwynir yn Gymraeg yn cael ei thrin yn llai ffafriol na chais a gyflwynir yn Saesneg.
An application form may be submitted in Welsh; any application submitted in Welsh will not be treated less favourably than an application submitted in English.
In action?
Step: If information materials need to be published in English and Welsh separately e.g: an application form: the following sentence should be placed on the front page of the English document(s):
Mae’r ddogfen hon hefyd ar gael yn Gymraeg.
This document is also available in Welsh.
In action?
Step: Where an email address or phone number is used to ask people to get in touch, the following sentence is included in the poster, email or public notice.
Mae croeso i chi gyfathrebu â ni yn y Gymraeg.
You are welcome to communicate with us in Welsh.
In action?
Step: The invitation to apply for the grant include questions to allow the applicant to consider the effect of the activity on the Welsh language. Example:
Let us know:
- what effects will the activity have on the Welsh language, and are those effects positive or negative?
- what steps will be taken to increase the positive effects and decrease any negative effects?
In action?
Step: When assessing applications for the grant, consideration is required as regards:
- what will be the effects of awarding the grant on the Welsh language, and are those positive or negative?
- how the decision can be made or implemented to increase positive effects and reduce adverse effects
- do we need additional information from the applicants to consider the effects on the Welsh language?
It is advisable to use the template for assessing effects, which can be found in Appendix 2
In action?
Step: If you arrange a meeting to ask further questions in relation to the application, you have included the active offer: (Includes hybrid and virtual meetings.)
- Croeso i chi ddefnyddio’r Gymraeg yn y cyfarfod dim ond i chi roi gwybod i ni erbyn xx/xx/xx.
- You are welcome to use Welsh at the meeting, just let us know by xx/xx/xx should you wish to do so.
In action?
Step: When you inform an applicant of your decision in relation to a grant application, you must do so in Welsh if the application was submitted in Welsh.
In action?
Step: You have imposed a grant condition to ensure more positive impacts on the Welsh language: see examples Section 4: Standard conditions that could be imposed for all grants, Pembrokeshire Coast National Park Authority’s Policy on Awarding Grants.
In action?
Step: The candidate’s language choice must be respected during the whole process.
In action?
Step: Keep a record the total number of grants distributed, along with recording:
- Number and % of applicants that have submitted their applications in Welsh, and how many have applied to conduct the interview for a grant in Welsh, as part of your assessment of the application.
- Number of organisations that have further developed their use of Welsh as part of the conditions to receive a community grant
In action?
Appendix 2: Template for assessing effects
Name of Grant:
Name of Applicant:
Part 1: Identifying effects on Welsh language
What would be the effects of awarding the grant on opportunities to use the Welsh language?
Positive effects:
Negative effects:
What would be the effects of awarding the grant on treating the Welsh language no less favourably than the English language?
Positive effects:
Negative effects:
Part 2: Identify additional information
Is additional information required to assist with the decision?
Part 3: Taking and implementing the decision
How could the decision be adapted to increase positive effects on the Welsh language?
Taking Decision (e.g: whether to award/ sum to award):
Implementing Decision (e.g: setting conditions):
How could the decision be adapted to reduce negative impacts on the Welsh language?
Taking Decision (e.g: whether to award/ sum to award):
Implementing Decision (e.g: setting conditions):
Policy Control
Change Level: New Policy or Change requires NPA Approval
Consultation: Management Team 11/6/24, 9/7/24
Assessments: N/A
Approval: National Park Authority, 24/7/24
Version History:
Version – V1
Active Date – 24/7/24
Summary of Changes – New Policy
Review:
Version – V1
Active Date – 24/7/24
Document Owner – Democratic Services Manager
Review Date Trigger – 3 year review cycle