Jocelyn Davies AM


Leighton Andrews

Minister for Public Services

Welsh Government

5th Floor

Tŷ Hywel

Cardiff Bay

CF99 1NA


30th October 2014


Re: The Gender-based Violence, Domestic Abuse and Sexual Violence (Wales) Bill

Dear Leighton,

I am writing to you on behalf of the Cross Party Group on Violence against Women and Children about the Domestic Abuse, Gendered Violence and Sexual Violence (Wales) Bill. We met on 21st October to discuss our response to the Bill and agreed on the following points.

The CPG welcomes the introduction of the Bill and we hope that it can be a landmark in the campaign against violence against women and children in Wales. While much in the Bill is to be welcomed, we believe that the preventative purpose of the Bill is lacking. We agree that we must work together to strengthen the Bill. Opportunities to legislate to end violence against women and children are rare and we must seize this opportunity while we can.

The CPG feels strongly that the gender neutral title and contents of the Bill undermine its purpose to improve the prevention of violence against women. Prevention can only be achieved by bringing about attitude change in society. This is not possible unless we acknowledge and understand the gendered nature of domestic abuse and sexual violence. The Bill should balance specifically tackling the culture of violence against women and girls with gender appropriate service provision that includes services for all victims, regardless of gender. We were pleased to hear that the Government will be amending the Bill to introduce gender specificity and look forward to seeing these changes in the near future. We very much support this change of heart.

The lack of education in the Bill is hugely disappointing following the strength of the plans originally outlined in the White Paper. The CPG agree that a statutory requirement on schools to provide compulsory healthy relationships education is fundamental to successfully preventing violence against women and children in our communities. Non-statutory PSE lessons delivered by teachers who may not feel comfortable with the issue or one off sessions that lack follow-up support have failed to achieve wholescale change in attitudes. The CPG would like to see a whole-school approach to educating all children and young people from an early age, including those that are not in mainstream education, on relationships, tolerance and equality. Healthy relationships education is the key to challenging gender stereotyping and thereby normalising equality, which in turn helps to raise educational attainment.

The CPG welcomes the creation of a statutory post for an advisor on gendered violence, domestic abuse and sexual violence. However, we are concerned that there is a lack of clarity about the scope of the role as currently outlined in the Bill. We would like to see an independent advisor with adequate powers to take the lead in tackling violence against women and children. We hope to see clarification from the Government on the scope of the ministerial advisor role as the Bill progresses through the Assembly.

            We all feel that the provision of services for perpetrators is an effective measure in the prevention of violence against women and children and the CPG is concerned that it is not included in the Bill. Abusers are some of the offenders who are most likely to reoffend and failing to break patterns of violence and abuse not only harms victims but also places a burden on public services that could be prevented. We hope that the Government will consider including work with perpetrators in the Bill, perhaps it could be included in the national strategy. However, above all we are concerned that services to victims are preserved.

Finally, the removal of the reasonable punishment defence when parents and other carers hit their children has proved divisive during the first stage of committee scrutiny of the Bill. However, after extensive discussion the CPG agree that we must stand together and take a cohesive position against violence against women and children in all its forms. Removing the reasonable punishment defence sitting alongside the educational provisions we want to see will send a strong message that will help to contribute to the culture change that will be vital if domestic abuse is to be seriously challenged. We see this move as fitting perfectly with the preventative purpose of the Bill. We hope that the government will reconsider its current position on the reasonable punishment defence and act in accordance with Welsh Government policy over the last 12 years by finally abolishing it.

Yours sincerely,

Jocelyn Davies

On behalf of the Cross Party Group on Violence against Women and Girls, which includes representatives from:

South Wales Police

The Survivors Trust Cymru

Citizens Advice Cymru

Port Talbot and Hafan Women’s Aid

Safer Wales

Hafan Cymru

Welsh Women’s Aid


Children Are Unbeatable