From low diversity in clinical trials to greater disparities in uptake: Module 4 of the Covid-19 Inquiry considers how the UK’s vaccination rollout scheme impacted minority ethnic communities during the pandemic.

The UK Covid-19 Public Inquiry recently concluded its Module 4 hearings. Module 4 covered the Government’s development of Covid-19 vaccines and therapeutics and the implementation of the vaccine rollout scheme throughout the UK’s four nations.

Saunders Law represents the Federation of Ethnic Minority Healthcare Organisations (‘FEMHO’), whose interests in this Module centre around whether structural inequalities, including scant regard for the public sector equality duty (‘PSED’) and equality impact assessment, influenced the development, efficacy and rollout programme of vaccines and therapeutics to Black, Asian and Minority Ethnic healthcare workers and communities. The hearings ran over a three-week period in January 2025, during which Saunders’ client, Dr Salman Waqar of FEMHO gave powerful evidence about his experience which drew from his dual perspective as both a medical professional on the NHS frontline and a member of a subgroup who faced ethnic disparities first hand.

The public hearings opened with an Impact Film shown to contextualize the purpose of the hearings. It featured the varied experiences of individuals and their families who took-up the Covid-19 vaccine. Opening statements were then heard from 17 Core Participants over the first two days followed by a further 12 days of live evidence.

Ultimately, the evidence adduced relating to racialised disparities revealed the following:

- There were significantly lower rates of recruitment of ethnic minority participants in vaccine clinical trials. This was particularly problematic in the later phases of trials when diversity was key to not only assessing risk-benefit but also to being able to reinforce and reassure these same minority groups that the vaccines were (and are) in fact tried, tested, safe and effective for them.

- Most Government witnesses admitted that they knew pre-existing health inequalities, low confidence and racial disparities were going to impact engagement with the vaccination programme among ethnic minority groups. Matt Hancock, Kemi Badenoch and other Government officials opined that they recognised in advance that significant steps were going to be needed to reach and engage these communities effectively.

- We heard that the Government’s Joint Committee on Vaccination and Immunisation (‘JCVI’) identified Black, Asian and Minority Ethnic groups as “high risk” suffering both higher rates of infection and higher rates of serious disease, morbidity and mortality, and thus directed the Government to make sure steps were in place to boost uptake among these groups.

- We heard that tailored public messaging was key to the success of the vaccination programme, and the two main factors to this type of messaging were (1) utilising TRUSTED VOICES as a resource to target ethnic minority communities; and (2) TACKLING MIS AND DIS-INFORMATION which was undoubtedly an issue among ethnic minority groups in a greater capacity than any other group.

- Although the Government did set up initiatives, like the Community Champion Scheme in December 2020 for example, which was specifically designed to utilise trusted voices within minority ethnic communities, the success of these initiatives was heavily questioned (including by FEMHO), for failing to go far enough quickly enough to reach these groups on a wide enough scale. As Dame Catherine Bingham (Former Chair of the UK’s Vaccine Taskforce) put it “we had different pots of grant money that's available for different things with no overarching leadership” .

- We heard evidence that FEMHO members (as well as many others) were ready and willing to help engagement efforts, and help they did, but often with little to no funding or support made available by central Government. This meant that far too often those who wanted to collaborate with the Government on messaging were instead forced to carry out initiatives independently. They reported hosting webinars, going on radio shows and even teaming up with companies like Facebook to produce a wide array of content dispelling misinformation, initiatives that could have been supported by Government to ensure wide-spread reach.

- We heard that the Government’s central reporting system, the Yellow Card Scheme, which was designed to encourage members of the public to report any adverse effects, was not widely known about and proved functionally limited for being hard to find on the website and unavailable in a range of different languages - two things that limit accessibility for ethnic minorities communities in particular.

- Finally, we also heard the devastating statistics around uptake of the vaccines, for example among the Black African and Caribbean population. The Government began the vaccine rollout in December 2020 with an ambitious target of achieving a 75% uptake rate across the UK. Yet despite the foreseeable disparities, only 62.2% of all adults, those aged 18 or over of Black African ethnicities had been vaccinated by April 2021 compared to 93.2% of White British people. We learnt that the level of coverage broadly across Black African ethnicities did not reach the 75% target until a whole year later, in June 2022, and in the same time period, Black Caribbean adults who had received two doses was just 59%, profoundly lower compared to the White British population by this date (90.3%).

FEMHO maintain that what seems to connect these issues of inequality and what came up as a constant and central theme throughout Module 4 (and has throughout the inquiry so far), is the matter of TRUST. There was a clear and continuing lack of trust in Government by ethnic minority groups who were understandably experiencing the vaccine rollout through the prism of their own pre-existing health inequities and past injustices. At the same time, there was an obstructive lack of trust by Government in trusted voices, community leaders and stakeholder groups alike, who in actual fact needed a government backed, co-ordinated and funded effort to reach the wide array of ethnic minority communities in our country, to dispel misinformation and encourage take-up of the vaccine. We say that what has really been exposed, is that too little has been done to build and maintain the trust of these groups for far too long, and we cannot afford the same to continue.

To conclude as part of closing statements, FEMHO focused its Module 4 recommendations on 9 key areas:

1) An acknowledgement that structural racism is a fundamental cause of racial disparities;

2) Funding for programmes in peacetime aimed at widening the use and effectiveness of engagement services;

3) The utilisation of trusted voices throughout the UK;

4) The creation and maintenance of systems that monitor ethnicity data across branches of government;

5) Deployment of enforceable measures to ensure that clinical trials in the UK actively recruit and represent ethnic minority communities;

6) Increase efficiency and access to safety monitoring systems such as the Yellow Card Scheme;

7) The creation of a future Vaccination Taskforce which is both diverse and inclusive of the communities it aims to reach and serve;

8) Investment in research and development; and

9) Recognition of the everyday heroes; the community leaders and healthcare professionals who played their part in helping the UK engagement effort during the rollout scheme.

We hope to see a bold stance taken by the Inquiry on these issues in its final report.

Saunders Law offers expert legal assistance and representation in all public inquiry cases, and we are well-known for our work and thorough approach to complex cases, please contact us on +44(0)207 632 4300, or fill in our online enquiry form if you would like our assistance and we would be happy to discuss your matter with you.