ALUMNI FOR FREE SPEECH UNCOVERS THAT LEADING UNIVERSITIES SPEND
OVER 200 TIMES MORE ON DIVERSITY THAN ON FREE SPEECH PROTECTION
EDI v Free Speech spending
AFFS issued a Freedom of Information (“FOI”) request to over 50 UK universities to find out what they are spending on Equality Diversity and Inclusion (“EDI”) departments and what they are spending on free speech protection. The great majority responded. The results are even more stark than we anticipated.
The 47 universities which provided relevant information employ 11 EDI staff on average. The 42 which also provided the costs of EDI staff and advice spent over £19.5 million between them at an average cost of £465,000 per university a year. UCL alone spends over £1 million a year employing 23 EDI staff. Only the LSE identified any expenditure on employees with specific free speech responsibilities (£71,300) and only Essex any expenditure on outside advice about free speech (£20,186). Leading universities are currently spending about 214 times as much money on EDI as on free speech protection.
The detailed findings are contained in the spreadsheet available via the link below. The spreadsheet contains links to the individual responses to our FOI requests and some methodological explanations. This document explains why AFFS believes that the uncontrolled expansion of university EDI departments poses a real and present threat to free speech and academic freedom and why universities need much better free speech infrastructure in order properly to comply with their existing and future legal obligations.
Universities’ abandonment of institutional neutrality
The expansion of EDI departments has led to an alarming decline of the institutional
neutrality that was once the norm at universities.
Ideological positions about race, gender
and national history which most of our universities now officially endorse have little or no
basis in either science or fact because they are neither verifiable nor falsifiable. They are highly
controversial, strongly contested academically and fundamentally at odds with the views of
most British people. Yet senior managers at our universities have empowered their EDI
departments to impose these ideologies on students and staff, including via so-called
Even where it is known to exist2
, some universities have declined to provide details of such
training, even under Freedom of Information (“FOI”) requests.3
Information provided by
whistle-blowers about its content has, though, led to public concern and press criticism.4
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English and Welsh universities are subject to statutory duties to protect free speech and
academic freedom.5 Under the Human Rights Act 1998 (whose provisions apply to all UK
universities), compelled speech is unlawful,6 and free speech in the academic setting enjoys
enhanced protection.7 Various philosophical beliefs contrary to those officially endorsed by
our universities are (or seem almost certain to be) protected under the Equality Act 2010
(which is also applicable to all UK universities).
8 Universities must avoid discriminating
against and harassing people with those beliefs. EDI training which requires people to
endorse views with which they don’t agree or which results in a hostile atmosphere for those
who dissent is, therefore, highly likely to be unlawful. Nonetheless, often-compulsory, EDI
training continues to exist and to encourage (and sometimes require) students and staff to
agree with the ideological opinions being pushed. Passing such training can sometimes be a
condition of being permitted to study or to work at our universities.
Relationships with external campaign groups and institutional capture
Like many other public institutions, our universities are now working hand in glove with
external campaign groups such as Stonewall9 and Advance HE10 and actively seek various
forms of accreditation on offer from them.
11 They appear unconcerned that these organisations
promote ideological agendas or that Stonewall also seeks to stifle debate of widely contested
issues, including via formal “no debate” policies. As well as being intolerant and illiberal, the
promotion of such agendas is likely to be contrary to universities’ own rules and, in many
cases, probably unlawful.
Institutional capture by lobbyists is currently so extensive, that EDI staff appear either
oblivious to or heedless of existing free speech protections.
For example, a document called “Tackling Racism on Campus Assets” published by Advance HE
in March 2021 was paid for by the Scottish Further and Higher Education Funding Council
and drafted by a Steering Group which included EDI managers at Glasgow, St Andrews,
Edinburgh and Heriot-Watt Universities with the “overwhelming support” of their respective
Principals.12 It uncritically advocated the controversial and contested “anti-racism” aspect of
Critical Race Theory. Among categories of university staff and students criticised were those
said to display “White Indifference” (itself said to be but one step away from “White
Supremacy”). According to the report, such obviously objectionable people can be identified
because they are: “Passionate defenders of western universalism, academic freedom and the right to
In common with public bodies like the BBC, Ofsted, Channel 4, the EHRC, the CPS, the
Cabinet Office and other government departments, increasing numbers of universities are
waking up to the dangers of unhealthy relationships with controversial lobbyists like
Stonewall and exiting from them. In England, UCL and LSE have led the way. In Scotland,
Edinburgh, Glasgow and St Andrews Universities have declined to renew their participation
one or other of Stonewall’s schemes. Other universities urgently need to follow suit. Most,
however, continue to have some association with Stonewall and some are doubling down. For
instance, despite having its relationship with Stonewall criticised by a senior barrister in a
report it commissioned into the cancellation of two external speakers in 2019 and 202014
University declined to adopt the report’s recommendation about the need to reform its
relationship with Stonewall15 and continues to celebrate its Stonewall accreditation.
Consequences for free speech
Universities’ abandonment of institutional neutrality about contested ideas has led to the
suppression of the free expression of lawful opinions at odds with EDI agendas, the
cancellation of events and has had severe consequences for people who dissent. All this, at
institutions whose role should be to encourage diversity of viewpoint and wide debate. In
such an atmosphere, self-censorship and public adherence to officially sanctioned dogma,
while understandable, is disturbingly commonplace. Both those in charge of universities and
those employed in their EDI departments continue, however, to deny the existence of any free
speech problem. At best, this is complacent. At worst, it is disingenuous. In the short period it
has been in existence, AFFS has encountered serious free speech compliance failures and
raised concerns about the lack of institutional neutrality with numerous universities.
• When Dr Helen Joyce was invited to speak at Gonville & Caius College, Cambridge its
senior leaders criticised her invitation, describing her views as “hateful to our
community”. Cambridge’s Sociology Department then apologised for even sharing
information about the event.17
• At Oxford University Professor Kathleen Stock, a gender-critical philosopher who was
hounded out of her job at Sussex University by trans activists18, needed security in order
to speak at the Oxford Union and had her speech disrupted by extremists.19
• Following baseless complaints of Islamophobia by students associated with its Islamic
Society about his viewpoints and the contents of a course he had taught for many years,
Bristol University failed to take any effective action to protect human rights expert
Professor Steven Greer from a terrifying social media campaign conducted in breach of
its own rules. Bristol then cancelled Professor Greer’s course even though it had entirely
exonerated him of any wrong.20
• An academic who criticised Edinburgh University’s decision to cancel Enlightenment
philosopher David Hume was subject to a campaign of harassment by student activists,
which the University failed to stop.
21 Other staff and student activists at Edinburgh have
twice physically prevented the screening the documentary “Adult Human Female” on
campus. The University did nothing to stop this unlawful interference with the free
speech rights of its members and has, so far, done nothing effective to ensure the event
can go ahead without further disruption.
• Despite the debacle involving Professor Stock, Sussex University has appointed its head
of EDI as its new lead on free speech,23 notwithstanding the continued presence on its
EDI website of inflammatory and abusive material castigating those who lawfully hold
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• St Andrews University sees no institutional neutrality issue with having the Chair of
Stonewall and the Chief Executive of Advance HE among the few external members of
its highest governing body.25 Like Sussex, it appears to regard freedom of speech as no
more than another facet of EDI.26
• At Durham University, it is reported that academics are afraid to voice dissent from its
thoroughgoing and official agenda of “decolonisation” of its curricula.
Regulatory response to free speech problems
The free speech problems at our universities meant that, as recently as December 2022, the
Office for Students (“OfS”) found it necessary to issue lengthy new guidance to universities
about “Freedom to question, challenge and debate”.
28 Among many important points, the OfS
pointedly made clear that the obligation to secure free speech: “is likely to entail a wide range of
steps needing to be taken in practice. In our view, it is unlikely to be sufficient for a university only to
make public statements in favour of free speech”.
The OfS’s guidance came in advance of the new Higher Education (Freedom of Speech) Act
- This Act:
• reinforces universities’ existing obligation to take all reasonably practical steps to secure
freedom of speech and enlarges it to include academic freedom;
• imposes a new statutory duty on universities’ governing bodies to promote freedom of
speech and academic freedom; and
• introduces both a formal free speech complaints scheme (to be overseen by the OfS and
a new Director of Freedom of Speech and Academic Freedom) and the right to bring
civil proceedings for free speech infringements.
The new obligations will also apply to constituent bodies (such as Oxbridge colleges) and, for
the first time, to students’ unions. If, as many Vice-Chancellors continue to maintain, there is
no free speech problem at our universities, there will be no complaints, nothing for the OfS
and the new Director to do and no court proceedings. AFFS believes that is very unlikely to
be the case and has already found it necessary to file formal complaints about free speech
failures with the OfS.
AFFS’s sister project, Best Free Speech Practice (“BFSP”)29
, has issued various briefing papers
about both the new requirements for universities and students’ unions and several specific
areas of concern30
, and is developing a comprehensive Statement of Best Free Speech Practice.
AFFS’ Freedom of Information requests
Because of the concerns discussed above, following our earlier FOI request for St Andrews’
comparative spending on EDI and Free Speech31
, AFFS decided to ask other universities for
similar information. At the end of March 2023, AFFS sent the same FOI request32 to a further
50 universities selected largely from a recent Guardian Good University List. We asked for:
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• the numbers of staff with EDI and Free Speech responsibilities; and
• the internal and external costs in the current year of employing such staff or buying in
external advice and training.
We have prepared a detailed spreadsheet of the universities’ responses, which can be found
here and includes links to all responses we received up to 31 August 2023.
Universities reacted in a variety of ways to our requests for information. Some provided
straightforward responses while others only answered certain queries or sought further
clarification before responding. There were instances of obfuscation33 but ultimately, most
universities provided the necessary data. A few universities refused to share what seemed to
be readily available information.
34 One sought to treat 17 identified senior managers with what
it calls “leadership responsibility” relating to free speech and academic freedom as therefore
employed in free speech focused roles and purported to identify their aggregate combined
salaries of £2.7 million as relevant free speech expenditure.35 Only one, Oxford Brooks, failed
to provide any answers at all.
These variable responses from the universities have, to some degree, influenced the results of
our survey. Consequently, despite a few striking instances of particularly high expenditure36
we are cautious about overly emphasising the relative performance of individual universities.
Their differing approaches could have been significantly impacted by how they interpreted
and responded to our FOI requests.
Nonetheless, AFFS is confident that the survey’s results offer a reliable comparative overview
of universities’ spending on EDI, and on free speech.
AFFS expected a discrepancy between staff and expenditure for EDI and for freedom of
speech compliance, but the results exceeded our worst expectations. In summary, and based
on the incomplete (and likely understated)37 information provided by universities in response
to our FOI requests:
• The 47 universities which provided any relevant information between them employed
515 people with EDI responsibilities, an average of 11 people per university.
• The 42 universities which provided any relevant information spent over £17.9 million
on EDI staff between them, an average of almost £427,000 per university.
• Of those 42, the 33 universities which provided any information about external
expenditure on EDI spent an additional almost £1.6 million between them on this,
raising average expenditure to £465,000.
• Of the 43 universities which provided any relevant information, 41 did not identify
anyone with specific responsibility for promoting and/or securing freedom of speech.
The remaining two between them employed not more than 5 people.
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• Of those 43 universities, only the LSE identified any expenditure (£71,300) on
employing anyone with responsibility for free speech.
• Of the 27 universities which provided any information on external advice and
materials relating to free speech matters only Essex identified any external
Overall, about 214 times as much money appears to be being spent on EDI as on free speech
Implications and proposals for improvement
The fact that universities employ virtually no-one to ensure compliance with their relevant
obligations suggests that they are not serious about free speech protection. Despite the stated
expectations of the OfS, universities appear to be doing little more than paying lip-service to
their statutory duties while continuing to fail to comply with them. This is entirely consistent
with AFFS’ correspondence with university leaders and external trustees, which has left us
with the strong impression that universities have deficient understanding of the nature and
extent of their obligations and have other priorities. Managers show little inclination to
confront staff or student activists and neither take the action required to protect free speech
nor have the right policies, rules, and procedures in place to enable prompt and firm action
when problems arise. As a result, universities’ governing bodies are failing to comply with
their existing legal obligations and seem unlikely to comply with their enhanced future
obligations without a significant change of attitude.
AFFS believes that free speech compliance at our universities is vitally, and increasingly,
Notwithstanding the increased scope for legal compulsion introduced (at least in England)
under the new legislation, AFFS believes that matters are unlikely to improve without a
change of culture. However, a return to institutional neutrality would contribute very
significantly to bringing this about. It should, for a start, lead both to withdrawal from current
unhealthy relationships with external campaign groups and to an immediate drastic
reduction in the numbers of EDI personnel whose activities are causing serious free speech
compliance issues at our universities. As things are, AFFS believes that by persisting in
endorsing disputed and contentious ideological views, and then imposing them on staff and
students through their EDI departments, universities are not complying with their obligations
under both university-specific legislation and relevant equalities and human rights laws.
The same obligations surely require universities to appoint properly empowered freedom of
speech officers, entirely independent of EDI departments. It is difficult to see how such officers
could or would permit EDI departments to continue to behave in the way they presently are.
Alumni For Free Speech
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13 September 2023
Alumni For Free Speech is part of DAFSC Ltd, company number 14189200. Registered office:
27 Old Gloucester St, London W1N 3AX.
@ DAFSC Ltd 2023
1 See, most famously, the Kalven Report:
See also, and more recently, the Chicago Principles: https://freeexpression.uchicago.edu/
2 E.g. at Kent and St Andrews Universities.
3 Responses to FOI requests AFFS has made of Kent and St Andrews can be read on its website.
AFFS is referring the refusal of these universities to disclose controversial training materials developed
with and/or purchased from third party vendors to relevant Information Commissioners.
4 See: https://www.dailymail.co.uk/news/article-10048411/Students-St-Andrews-told-pass-
andrews-rgcvcglx3; and https://www.thetimes.co.uk/article/the-times-view-on-the-bias-test-at-st-
andrews-university-beyond-all-reason-md3jf5lv8 (St Andrews); and
5 Under Section 43(1) of the Education Act (No.2) 1986; and soon under the Higher Education
(Freedom of Speech) Act 2023, in respect of English institutions only.
6 See, for example: Buscarini and others v. San Marino App. No. 24645/94 (1999).
7 See, for example: Asku v. Turkey (2013) 56 EHRR 4; and Sorguc v. Turkey App. No. 17089/03
8 See, for example:
Further, in May 2023, the Department for Work and Pensions paid Anna Thomas £100,000 just before a
case came to the Employment Tribunal which involved her claiming discrimination for being dismissed
following whistleblowing complaints voicing her concerns that the DWP’s adoption of aspects of
Critical Race Theory. Ms Thomas alleged that the distribution of materials asking white employees to
“assume” they were racist, was a breach of the Civil Service Code’s requirement of political impartiality
and could lead to discrimination against white people. Belief in Scottish independence can also count
as a protected belief (McEleny v Ministry of Defence, ET, 2019). So surely, can carefully thought-through
© DAFSC Ltd 2023 Page 8
viewpoints both for and against Brexit. Other, similar, claims are pending and the list seems likely to
continue to grow.
9 Universities often first became associated with Stonewall at a time when it was a highly
successful lobbyist for gay rights. More recently, however, and following the departure of some of its
founder members, Stonewall has taken up highly contested forms of trans activism, adopting an official
policy that there should be “no debate” about them (https://www.stonewall.org.uk/node/100426).
Endorsement of this agenda is now required of universities who participate (for a fee) in its Diversity
Champions Programme or who seek accreditation through its Workplace Equality Index.
10 As in the case of Stonewall, universities appear to have become involved with Advance HE
and, more particularly its Athena Swan Awards scheme, at a time when its work focussed on
improving the status and careers of female academics. As with Stonewall, however, Advance HE has
since started to advocate much more controversial and contested positions based on its uncritical
acceptance of trans ideology (https://s3.eu-west-2.amazonaws.com/assets.creode.advancehe-
he/Trans_staff%20and%20students_HE_guidance_1655287866.pdf), aspects of Critical Race Theory
(see: https://www.advance-he.ac.uk/anti-racist-curriculum-project#overview) and the supposed need
to decolonise university curricula (see: https://www.advance-he.ac.uk/sites/default/files/2021-
11 Like many other public bodies and companies, universities jockey with other employers for a
high position in Stonewall’s Workplace Equality Index. Some employ EDI staff whose sole role
appears to be to make applications for EDI-related Awards e.g. according to information it provided
pursuant to an AFFS FOI, St Andrews employs two dedicated “Awards Advisers” and an assistant.
University Court member, Professor Catherine O’Leary, is identified as Athena Swan Institutional
Chair, working with the EDI team to prepare its Silver Award application (https://www.st-
These employees are clearly having an effect according to St Andrews’ dedicated Athena Swan
awards page: https://www.st-andrews.ac.uk/hr/edi/sex_gender/athenaswansupport/. Somewhat
ironically, the only department so far to achieve the most coveted Gold Award is Biology which has
its own extensive EDI website (https://biology.st-andrews.ac.uk/edi/), and a, 26-strong EDI committee,
led by, Anti-Racism advocate, Professor Kevin Lala. Professor Lala’s, October 2022, lecture on
“Racism in Biology” (see https://biology.st-andrews.ac.uk/edi/anti-racism/) appears to have been
archived since AFFS expressed concerns about it. It can, though, still be viewed via the link in
footnote 9 to the letter referred to in footnote 25 below.
Other universities (e.g. UCL) also appear to have EDI employees solely dedicated to obtaining
13 See: the table on page 10. It is alarming that the EDI experts responsible for the report appear
to have been either ignorant of, or unconcerned by, the fact that the right to offend is specifically
established by both European and English human rights case law, see e.g. Handyside v the UK, App.
No. 5493/72 (1976).
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Attempts to require Essex to issue an unredacted version of the Reindorf Report are ongoing.
15 See: Recommendation 28 on page 86 and Essex’s response here:
17 AFFS has written to the Master, the Head of the Sociology Department, the College’s governing
Council and the University about these events. All to no avail. We have also reported the University’s
and the College’s failures to the OfS.
Caius Master letter 26.10.22
Cambridge Sociology letter 27.1.23
Caius council letter 7.12.22
Cambridge council letter 17.11.22
Letter to OfS and EHRC re Cambridge
18 See: https://www.theguardian.com/world/2021/oct/28/sussex-professor-kathleen-stock-
20 See AFFS’s letter to Bristol dated 11 April 2023 and its subsequent letter to the OfS and the
AFFS letter to Bristol 11.4.23
AFFS letter to OfS and EHRC re Bristol
Bristol’s failure to take any action to enforce its own rules in defence of Professor Greer goes to the heart
of the free speech issues at universities. Many are supine in the face of gross breaches of their own rules,
with the clear implication that they don’t understand or don’t care about their legal obligations, or are
frightened of the activists, or basically agree with them, or are too busy with other responsibilities to
take the action they should be taking – or a combination of the above. A key problem is that, at best,
very few of them have any individual with the designated responsibility, and the focus, time, seniority,
powers, motivation and lack of conflicting responsibilities, necessary to take the lead on discharging
universities’ legal duty to secure free speech.
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22 Even though AFFS has repeatedly raised the free speech compliance issues arising from these
events with both Edinburgh’s most senior managers and with the Senior Lay Member of Edinburgh’s
Court (see: AFFS’ letters to Edinburgh dated 21 December 2022, 27 February 2023, 2 May 2023 and 16
May 2023 all linked below) no effective action has been taken either to hold those responsible to account
or to ensure that this lawful event can take place without further disruption.
AFFS letter to University of Edinburgh 21.12.22
AFFS letter to Janet Legrand KC (Hon) Senior Lay Member of Court University of Edinburgh 27.2.23
AFFS letter to Janet Legrand KC and Court members 2.5.23
AFFS letter to Janet Legrand KC and Court members 16.5.23
AFFS worries that this is only the start of a trend by which our universities, faced with firmer free
speech regulation, will seek to treat what are overarching and independent free speech obligations as
somehow inextricably tied to, or subordinate to, EDI initiatives notwithstanding that the ideologies
which EDI departments seek to impose and which universities officially adopt are plainly controversial
24 See: AFFS’ letter to Sussex dated 10 February 2023 (including footnote 12 on page 4). AFFS has
also taken these issues up with Sussex’s external trustees. They seem as unconcerned about them as
AFFS letter to Vice Chancellor
AFFS letter to Chair and Vice Chair
25 See: AFFS’ letter to St Andrews dated 21 February 2023.
26 St Andrews presently has no freedom of speech or academic freedom code but says it intends
to include free speech principles within a new “Diversity Action Plan” being drafted by its EDI
department (see letter referred to in footnote 25 above).
As also reported (https://www.telegraph.co.uk/news/2022/04/09/decolonise-maths-subtracting-white-
male-viewpoint-urges-durham, Durham’s mathematicians are especially keen on decolonisation:
inclusion/decolonisation/: as, apparently, are: its theologians
processes/curriculum/decolonisation/; its philosophers
inclusion/); its musicians (https://www.durham.ac.uk/departments/academic/music/about-
us/equality-diversity-and-inclusion/); and its historians
Given that it is reported that academics are afraid voice dissent from this agenda, AFFS has written to
Durham about the legal and compliance free speech risks of and enforcing such policies.
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AFFS letter to Durham re decolonisation
29 For further information about BFSP, see: https://bfsp.uk/.
30 BSFP has so far produced Briefing Notes for universities about:
(1) Philosophical beliefs protected under the Equality Act: https://bfsp.uk/wp-
(2) Free Speech Protection at English Universities post the 2023 Act: https://bfsp.uk/wp-
(3) Free speech protection by Students’ Unions of English universities: https://bfsp.uk/wp-
(4) Free Speech Governance, Officers and Reporting: Requirements for English Institutions:
(5) “Decolonising the curriculum”: Free speech compliance risks for English universities:
(6) Minimum requirements for staff and student behaviour: https://bfsp.uk/wp-
(7) Introductory courses, training and tests for students: https://bfsp.uk/wp-
31 St Andrews’ answer generated significant press interest. See: an article in the Sunday Times of
23 April 2023 titled “St Andrews University criticised for spending on diversity staff” (available on its
website) and this article in the Herald
32 AFFS Freedom of Information Question
33 E.g. Imperial College London, who initially asserted that AFFS’ requests were “vexatious”
but, once we had explained to its FOI Department why that was legally untenable and said we would
complain to the Information Commissioner, revealed that: it employed 15 EDI staff at a cost of over
£700,000, spent over £57,000 on Stonewall and Athena Swan memberships and an additional almost
£32,000 on external EDI training, but spent nothing and employed no one to secure compliance with
its freedom of speech obligations: https://affs.uk/wp-content/uploads/2023/09/Imperial.pdf.
34 E.g. a number, including Birmingham University, maintained that it would take more than the
maximum limit of 18 hours required under FOI legislation to gather the information requested, while
Durham University maintained that it did not hold relevant information ”to this level of detail”
(https://affs.uk/wp-content/uploads/2023/09/Durham.pdf) despite its, 10-person, EDI team being
separately identified on its website: https://www.durham.ac.uk/about-us/professional-
35 In response to AFFS’s request that it identify people wholly or partly employed in relation to
promoting and/or securing freedom of speech and academic freedom (i.e. the free speech equivalents
© DAFSC Ltd 2023 Page 12
of those specifically employed in relation to EDI), Essex University only replied on 31 August, saying
that the promotion and/or securing of free speech and academic freedom was “the responsibility of all
staff” and identified 17 senior members of staff (including its Vice Chancellor, Deputy Vice-Chancellor,
Registrar and Secretary, Director of Finance Planning, the Executive Deans of its Social Science, Arts
and Humanities and Science and Health Faculties and its Director or Inclusion) as having “leadership
responsibility that relates directly to this area of work”. This appears not to address the thrust of our
question, which is whether promoting and/or securing free speech is part of the specific duties of the
officer concerned (i.e. likely part of their job specification) in respect of which the officer actually spends
a material proportion of their time, rather than having it as a generic responsibility along with all other
staff. Essex then identified what appears to be simply the aggregate salaries of all these senior staff
(£2.7m) as relevant expenditure on free speech equivalent to its expenditure of over £500,000 on its EDI
AFFS will be writing to Essex to seek clarification of the correct numbers and figures, and will, of course,
readily revise its spreadsheet to include such numbers and amounts (if any) as Essex confirms are
correct in this context. Pending such confirmation, however, the £2.7m Essex spent on these 17 senior
managers’ total salaries is not included in our spreadsheet in respect either of their general managerial
responsibility for free speech or in respect of the general managerial responsibility they are also said to
have for EDI in Essex’s response.
36 E.g. Lancaster University spent over £800,000 employing no fewer than 26 EDI staff, City
University spent almost £875,000 on 17 EDI staff and UCL over £1 million employing 23.
37 The global figures seem bound to understate the true numbers of staff employed by and total
EDI spending at universities, given that: (1) the most common forms of incompleteness were a failure
to provide any relevant information at all and providing no figure of spending on external EDI input;
(2) for Oxbridge, we only obtained information for the central administrations of the universities and
not, in addition, for separate Colleges and (3) the figures given do not include any