03. Diversity & Equal Opportunities Policy
The Company is committed to the principle of equal opportunities in employment and are opposed to any form of less favourable treatment or financial reward through any forms of discrimination, harassment, bullying, victimisation on grounds of a persons protected characteristics under the Equality Act 2010 – age, disability, gender reassignment, marriage, or civil partnership, race, religious or belief, sex or sexual orientation.
Please note that gender reassignment, marriage, civil partnerships, pregnancy and maternity are currently protected under sex discrimination law. The Equality Act 2010 does not add any protected characteristics to those already defined by law.
This policy applies to job applicants (both internal and external) and all employees whether full time, part time, casual, temporary, and seasonal contracts. The policy also applies equally to the treatment of clients, members and suppliers.
This policy applies to employees, job applicants (both internal and external) and all workers whether full-time, part-time, casual, temporary, seasonal or contract. The policy also applies equally to the treatment of customers, students, clients and suppliers.
1. Types of Discrimination
There are various types of unlawful discrimination. Discrimination may occur intentionally or unintentionally.
Direct discrimination : Direct discrimination occurs where someone is treated less favourably than another because of a “protected characteristic” as set out in paragraph 2 above. For example, rejecting an applicant of one race because it is considered that he/she would not “fit in” on the grounds of his/her race could be direct discrimination.
In limited circumstances, employers can directly discriminate against an individual for a reason related to any of the protected characteristics where there is an occupational requirement.
The occupational requirement must be crucial to the post and a proportionate means of achieving a legitimate aim.
Indirect discrimination : Indirect discrimination occurs where a provision, criterion or practice which applies to everyone particularly disadvantages people who share a protected characteristic (although it does not explicitly include pregnancy and maternity which is covered by indirect sex discrimination) and it cannot be shown to be a proportionate means to achieving a legitimate aim. Indirect discrimination can be justified if it is possible for an employer to show that they acted reasonably in managing their business.
Harassment : occurs where there is unwanted conduct, related to one of the ‘protected characteristics’ (other than pregnancy and maternity and marriage and civil partnership) that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

Victimisation: occurs when an employee is subjected to a detriment such as, for example, being denied a promotion because he/she made or supported a colleague’s complaint or raised a grievance under the Equality Act 2010 or is suspected of doing so.
Associative discrimination: occurs where an individual is directly discriminated against or harassed due to his/her association with another individual who has a ‘protected characteristic’ (although it does not cover harassment because of marriage and civil partnership and pregnancy and maternity). For example withdrawing a promised promotion to an employee because he/she has a sick parent on the grounds that he/she will not have time to concentrate on the new job. This may amount to discrimination against the employee because of association with a disabled person.
Perceptive discrimination: is where an individual is directly discriminated against or harassed based on a perception that he/she has a particular ‘protected characteristic’ (other than marriage and civil partnership and pregnancy and maternity) when in fact he/she does not.
For example, someone who looks younger than he actually is and is thereby refused the opportunity to represent his company at a meeting because he is deemed too young, is discriminated against on the perception of his age.
Third-party harassment: this occurs where an employee is harassed and the harassment is related to a ‘protected characteristic (other than marriage and civil partnership and pregnancy and maternity), by a third party such as clients or parents.
Failure to make reasonable adjustments: occurs where a physical feature or a provision, criterion or practice puts a disabled person at a substantial disadvantage compared with someone who does not have that protected characteristic and the employer has failed to make reasonable adjustments to enable the disabled person to overcome the disadvantage.
1. Employment Practices
It is the duty of all employees to accept their personal responsibility for adhering to the principles of equal opportunity and maintaining racial harmony. The Company actively promotes equal opportunities and diversity awareness throughout the Company to ensure that individuals receive treatment that is fair and equitable and consistent with their relevant aptitudes, potential skills and abilities. Employees will be recruited and selected, promoted and trained on the basis of an objective criterion. The Company recognises that sexual, racial and other forms of harassment may cause problems at work and is committed to ensure that unacceptable behaviour does not take place.
Positive action provisions of the Equality Act: Employers can treat applicants/employees with a protected characteristic more favourably than others in connection with recruitment or promotion. This applies only to candidates of equal merit and the more favourable treatment must enable/ encourage an employee to overcome or minimise a disadvantage where he or she is currently under-represented

2. Monitoring and Review Arrangements
The Company will regularly monitor its policies to ensure that it continues to pursue an effective policy of equal opportunity.
3. Grievance and Disciplinary Procedures
The Company will ensure that any employee who feels that he or she has been treated unfairly or subjected to direct or indirect unfair discrimination can raise the matter through the Company’s grievance procedure when every effort will be made to secure a satisfactory resolution.
The Company will ensure that any employee making a complaint of unfair discrimination will be protected from any victimisation in any form and will continue to treat unfair discriminatory conduct by any member of staff as a disciplinary offence.
Where an employee is falsely accused of discriminatory conduct, then he or she may implement the Company’s grievance procedure. In this instance, the person who made the false accusation will be subjected to disciplinary action. In serious cases, such behaviour may be deemed to constitute gross misconduct and may result in summary dismissal in the absence of mitigating circumstances.
4. Training
The Company will train, develop and promote solely on the basis of merit and ability and will seek to encourage employees and suitably qualified applicants from all sectors of society.
5. Rehabilitation of Offenders
The Company will not discriminate against anyone who has a spent conviction as defined by statute. It is unlawful to refuse to engage or to dismiss on the grounds of a spent conviction.
A conviction becomes spent after a period of time that runs from the start of the sentence.
6. Recruitment and Promotion
When establishing criteria for recruitment and promotion into vacant posts, the Company will consider carefully whether any minimum or maximum number of years of relevant experience is necessary for the effective performance of the job. Such restrictions will not be imposed unless there is a proper job-based reason why they are necessary i.e. age for insurance purposes.
The composition of the workforce and of job applicants will be monitored and if necessary action will be taken to redress any imbalance should inequalities become apparent.
7. Equal Pay & Benefits

All reasonable steps will be taken to ensure that male and female employees receive equal pay for the same work and for work rated as equivalent and for work of equal value.
The Company will continually review existing and future pay policies and structures to monitor the impact of such policies and structures and will accordingly fairly pay all its employees, justly rewarding everyone for their contributions to the Company’s continuing success.
Where increased pay and/or enhanced benefits are offered to employees on the basis of length of service, these are intended to reward loyalty, maintain motivation and reflect higher levels of relevant experience.
8. Working Environment
The Company prohibits the display of any offensive material e.g. sexually offensive pin-ups and poster and will if necessary ensure that the workplace is inspected and offending material removed.
All new employees will be informed of the Company’s policy towards harassment at induction training, when it will be stressed that all complaints of harassment will be treated very seriously.
9. Bullying and Harassment at Work
Bullying and harassment is unsolicited and unwelcome behaviour that adversely affects the dignity of the recipient. Where the behaviour is motivated by gender, marital status, age, race, colour, national or ethnic origin, nationality or disability it also amounts to infringement of equal employment opportunity. Also, in some instances constitutes a criminal offence.
The Company is committed to ensuring that no bullying, harassment or victimisation at work, whatever the motivation, is overlooked or condoned. Such behaviour can range from extreme forms such as violence or bullying to less obvious actions like practical jokes and ridiculing colleagues or subordinates.
Conduct becomes bullying or harassment if it persists when it has been made clear that the recipient regards it as offensive, although a single offensive act can amount to harassment if it is sufficiently serious.
Any form of bullying or harassment will be considered a potential disciplinary matter.
Sexual Harassment at Work
Sexual harassment is a particular form of harassment. It is conduct directed towards an employee by another employee or group of employees which is of a sexual nature, or which is based on a persons gender, and which is regarded as unwelcome or offensive to the recipient.

The following are examples, which illustrate the sort of conduct that may be treated as sexual harassment. This is not an exhaustive list:
 uninvited and unwanted physical contact or conduct that is intimidating, physically or verbally abusive. Harassment can also be non-verbal, for example, staring or gestures;
 suggestions that sexual favours may further a person’s career, or that refusal may hinder it;
 sexual advances, propositions, suggestions or pressure for sexual activity at or outside work;
 derogatory or demeaning remarks based on gender, or the display of sexually explicit material in the workplace.
 insensitive jokes and pranks that are sexual or sexist.
 remarks or banter that have a sexual content
 speculation about a person’s private life and sexual activities.
Sexual harassment is a form of denial of equal employment opportunity that has the effect of insulting and demeaning the employee who is harassed.

Racial Discrimination (Racial Harassment)
Racial harassment is a particular form of harassment. It is conduct directed towards an employee by another employee or group of employees which is of a racial nature, or which is based on a persons ethnicity, race, colour or origins, and is regarded, by the recipient, as unwelcome or offensive.
The following are examples that illustrate conduct, which may be regarded as racial harassment. This is not an exhaustive list:
 jokes about race.
 offensive names used.
 references to people by offensive racist descriptions.
 verbal or physical abuse because of a person’s race or colour.
 detrimental behaviour because of a person’s race.
 denial of opportunity because of race
 remarks and banter that have a racial content or are racist in nature.
 deliberate exclusion from conversations on racial grounds.
 displaying racially abusive writing or pictures.
Religious and Cultural Needs
Some employees may have special needs because of distinct cultural, religious and possibly language difference.
All Company regulations, particularly those relating to health and safety and communications should be simple and effective. Pictures or diagrams may be more useful than written signs.
Consideration needs to be given to working practises and whether changes are possible to allow observations of prayer times and religious holidays and culture (e.g. traditional dress)
The following are examples that illustrate conduct, which may be regarded as harassment.
This is not an exhaustive list:
 insensitive jokes or pranks linked to religion or belief
 remarks or banter about religious beliefs

 abusive, threatening or insulting words or behaviour on grounds of religion or belief
 displaying writing or pictures that are abusive towards a particular religion.
Sexual Orientation
Sexual harassment based on sexual orientation is a particular form of harassment. It is conducted directed towards an employee by another employee or group of employees which is based on a person’s gender, and which is regarded as unwelcome or offensive to the recipient.
The following are examples, which illustrate the sort of conduct that may be treated as sexual harassment. This is not an exhaustive list:
 insensitive jokes relating to sexual orientation
 remarks or banter about gay or lesbian people
 displays of sexually offensive material relating to sexual orientation e.g. emails with offensive attachments.
 pranks perpetrated on grounds of a person being gay, lesbian, bi-sexual and transvestites.
 speculation about a person’s private life and sexual activities.
Age Discrimination
Any harassment to do with age which is conduct directed towards an employee by another employee or group of employees which is of an ageist nature and is regarded, by the recipient, as unwelcome or offensive.
The following are examples that illustrate conduct, which may be regarded as racial harassment. This is not an exhaustive list:
 insensitive jokes that make fun of older people
 remarks or banter about older or younger people
 pranks perpetrated on age grounds
 deliberate exclusion from conversation on grounds of age
 a refusal to co-operate with someone on grounds of a perception that he or she is “too young” or “too old” to bother about.
 treating someone’s ideas as inferior or worthless on account of youth.

 making demeaning remarks (whether in fun or not) alleging that someone’s physical or mental abilities have declined on account of his or her age.
Dealing with Harassment, Bullying and Victimization
The Company’s aim when dealing with alleged harassment is to resolve the complaint sensitively, impartially, effectively and quickly.
Informal Complaints Process
The recipient of the alleged harassment may wish to endeavour to resolve the matter informally by talking directly to the person responsible for the offending conduct.
Formal Complaints Process
If you consider that you are being subjected to harassment, bulling and victimisation and you do not wish to deal with the matter informally you should make a complaint to your Line
Manager or if the complaint is about your Line Manager, then to the Chief Executive.
Depending on the seriousness of the allegation the alleged harasser may be suspended on full pay while the matter is being investigated in accordance with the Company’s disciplinary procedures. Neither complainant nor alleged harasser will be victimised in any way.
The Making Of A Malicious Complaint That Is Known To Be False Will Be Regarded As
Misconduct.
Where an employee is found to have harassed another employee the Company will, following the disciplinary procedure, decide the appropriate action (if any) in the light of all the evidence. Such action may include dismissal, a job transfer, or counselling. Where a harasser is retained in employment, the Company will monitor the situation to ensure that the harassment has stopped.
It is a disciplinary offence to victimise or retaliate against an employee, who has, in good faith, made, supported or assisted in the making of a complaint of harassment. There will be no victimisation of any employee for making or supporting or assisting a complaint of harassment
– even if the complaint is not upheld – provided the action was taken in good faith.
10. Discrimination Policy on Grounds of Disability
Discrimination on grounds of disability is a breach of equal opportunities. Also there is specific law prohibiting such discrimination.
Any employee who believes that he or she has been unfairly discriminated against for reasons related to their disability should invoke the Company’s grievance procedure.
Recruitment

i) Recruitment will be on the sole basis of the applicant’s abilities. A disability will not of itself justify the non-recruitment of an applicant. ii) Reasonable adjustments to the application procedures will be made as required ensuring that applicants are not disadvantaged because of disability. For example where written tests are used alternative arrangements will be made for visually impaired applicants. iii) Before an applicant is judged because of a reason related to their disability to have failed to meet the requirements of their job description and personal specification or to been less suitable than other applicants. Full consideration will be given as to whether a reasonable adjustment can be made which will counteract this disadvantage.

Induction i) When a disabled employee commences employment it will be the responsibility of the
Line Manager in consultation with the disabled employee to ensure that such reasonable adjustments are made as are required to enable him or her to work safely and effectively and to secure equal access to the benefits of employment. ii) Where relevant expertise to resolve the problem is not available the Company will consult as required an outside specialist.
Training and Career Development
I) All employees will have equal rights to training promotion and other aspects of career development based purely on their abilities. ii) In particular each element of the promotion procedure and all training will be made accessible to disabled employees by such adjustments as are reasonable. ii) Where during the course of their employment a disabled employee recognises their need for a reasonable adjustment to be made to employment arrangements or premises he or she should discuss this requirement with their Line Manager. The Line
Manager will then determine the appropriate action however if this cannot be accomplished then the issue will be directed to a member of the Executive Team.
Benefits i) Disabled employees will have equal access to all benefits and facilities and reasonable adjustments will be made where necessary. ii) The responsibility for implementation of the policy will lie with the Chief Executive.
Harassment
Harassment of disabled employees will be a disciplinary offence and may constitute gross misconduct.
Retention i) As part of its commitment to equal opportunities for disabled people the Company will ensure that all reasonable measures are taken to retain disabled employees in employment. ii) The responsibility of the implementation of this policy will lie with the Chief Executive. iii) It will be the responsibility of the Executive Team to identify when there is an issue of retention for an individual employee. For example where dismissal of a disabled person is being considered on the grounds of sickness or incapacity.

iv) The Company will make such adjustments as are reasonable to enable a disabled employee to carry out his or her duties. This will include but is not limited to consideration of the provision of specialist equipment, job re-design, re-training, flexible hours, remote working and/or re-deployment. v) If as a result of their disability an employee is absent from work for a period of 4 weeks a phased return to work should be arranged in consultation with their Line Manager. vi) During this period either side may request vocational, medical or functional assessment. vii) If re-deployment is necessary the employee will be viewed as a priority within the redeployment procedure.
Adjustment i) The prime responsibility for arranging the appropriate adjustment will lie with your
Line Manager. However in many cases a team approach by Senior Management team will be appropriate. ii) The person with responsibility for arranging adjustments will at all times consult with the employee concerned whose agreement will be sought. The expertise of the disabled employee concerning his or her own disability will be recognised. iii) Where the person with initial responsibility does not have the relevant expertise to resolve the problem they will consult a member of the Executive Team. Where required an outside specialist may be consulted with prior authorisation from the Chief
Executive. iv) Once an adjustment has been made this operation may need to be reviewed at agreed intervals to assess its continuing effectiveness.
Action Plan – Removal of Barriers i) The Company recognises the importance of taking pro-active measures to remove barriers to disabled people from the working environment. This will benefit not only disabled employees and prospective employees but also in many cases customers, visitors and staff who have temporary impairment for example a broken leg. ii) An action plan will be drawn up in consultation with the staff indicating which actions will be taken over a certain period of time and who has responsibility for various aspects of the plan and how it will be monitored. iii) The plan will address physical access to the premises, access to benefits of employment, terms and conditions of employment, recruitment and arrangements for recruitment, performance assessment, promotion and retention.

iv) The plan will consider the incorporation of access improvements into maintenance plans and any refurbishment or building works.