Reed in Partnership – Skills v2 June 2011 Diversity Policy All Co-Members, including associates and subcontractors must agree to adhere to this policy as a condition of their engagement. Statement of Intent There are many things we do well that encourage Diversity both within our organisation and in the wider labour market, of which we can justifiably be proud. However, in work I have undertaken for the Chartered Institute of Personnel and Development (CIPD) and the Institute of Public Policy Research (IPPR), I have been struck by how much work is still to be done across the private and public sectors if we are to achieve a truly diverse labour market and economy in which it can be honestly said that there is equality of opportunity for all based on merit. Reed performs an important role in the functioning of the labour market and it is our responsibility, as part of that role, to ensure that talent is recognised, developed and matched with business need, whatever the background or circumstances of the individual, irrespective of age, disability, race, religion or belief, sex, sexual orientation, gender reassignment, marriage or civil partnership status, pregnancy or maternity or dependents considerations. This policy sets out our business case for being a progressive force for diversity in the UK economy. It also sets out the situation internally within Reed, and it explains what some of the areas we seek to monitor and address are and how diversity is managed within the Reed family of companies. A Code of Practice section also provides practical guidance on supporting Diversity within our workplace and within the wider labour market for all CoMembers. This ensures that no-one is disadvantaged in any way because of a protected characteristic under the Equality Act 2010. Protected Characteristics are as follows: Age Disability Gender Race (including Nationality and Ethnic Origin) Religion or Belief Sexual Orientation Gender Reassignment Marital or Civil Partnership status Pregnancy and Maternity Appendix A at the end of this Co-Member Handbook provides further guidance on UK legislation relating to Diversity. What is Diversity? Diversity is a concept which recognises the benefits to be gained from differences. This is in contrast to Equal Opportunities which has traditionally been a concept which sought to legislate against discrimination. Diversity management therefore not only deals with issues of discrimination but is also about ensuring that the talents of all Co-Members and Members are recognised and that they are able to maximise their potential and their contribution to our organisation and the wider labour market, whatever their background or circumstances in relation to age, disability, race, religion or belief, sex, sexual orientation, gender reassignment, marital or civil partnership status, pregnancy or maternity or dependants considerations. Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 Why is Diversity Important to Reed? Reed’s success depends, in part, upon our ability to lead and create positive social change in the labour market. Our businesses: Improve people’s labour market prospects Make the labour market fairer and more efficient Reed therefore performs an important role in the functioning of the labour market and it is our responsibility, as part of that role, to ensure that talent is recognised, developed and matched with business need, whatever the ethnic or religious background of the individual, irrespective of age, sex, marital or civil partnership status, sexual orientation, disability or dependants considerations. Reed not only seeks to effect change in the labour market but to grow its businesses and be profitable. In addition to our ethical role in the labour market there are also clear business benefits for Reed in actively pursuing Diversity. Accessing Untapped pools of Talent Older workers, those with disabilities, ethnic minorities and women are under-represented in the workforce for a variety of reasons. Broadening our appeal to such Members and seeking to include them in the services we offer can only maximise our chances of providing employers with the broadest range of talented individuals suitable for their vacancies. In a tight and competitive labour market such as those in which we operate this can only be to our competitive advantage. Diversity increases Creativity Reed thrives on new ideas and entrepreneurialism. Ideas are often generated when the different experiences and backgrounds of our Co-Members are brought to bear on a particular topic. It is not, therefore, just that we value difference but that difference creates value in our organisation. Customer Expectations Our public sector funders clearly expect and require assistance towards meeting their statutory duty to promote diversity. The employers we work with increasingly view diversity as an essential part of their own corporate brand and want the same responsible and forward looking attitude from all their advisers and suppliers. Need to be Our Own Best Case Study As a leading provider of welfare to work, skills development and business support services we need to be our own “best case study” and to exemplify how private sector organisations should encourage diversity. We need to demonstrate our progressive commitments and activities to key business influencers, including the media, the political audience and most importantly to all of our customers. If we cannot demonstrate to our customers that we can do it for ourselves why is a customer going to be believe that we can do it for them? Positively Support our Legal Obligations We need to positively support our legal obligations to Co-Members and other stakeholders. The reward for being a trusted expert on recruitment and employment legislation is that our reputation and business are enhanced, whereas the costs of non-compliance can be considerable. Employee dissatisfaction and ultimately Employment Tribunals could consume large amounts of management time and entail legal costs quite apart from the damage to our reputation and ability to win new business. Better Recruitment, Retention and Morale among Co-Members Co-Members want to work for a company that is seen to treat its staff fairly. Fair and equal treatment and a positive picture of diversity in Reed improves morale and consequently retention and makes us a more attractive place to work for potential applicants. Only by becoming a more diverse place in which to work will we become an employer of choice. Local Labour Market Expertise Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 In order to maximise our business success our Co-Members need to understand the local labour markets and business environments in which they operate. Co-Members from diverse backgrounds that reflect different perspectives from within that labour market, whether white, ethnic minority, disabled, male, female, young or old can only increase our understanding of complex local labour markets and businesses. Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 Reflecting the local community Many of our operations are open to the general public. Where Members, funders, employers and partners have the choice, many would rather work with a company that represents their local communities than one that doesn’t. Brand positioning By being positive in this area we move our brand towards the acquisition of previously underutilised human capital and customers that would not otherwise have come to us. 20.4 How is Diversity Managed within Reed in Partnership? Policy All Reed companies have a broadly similar diversity policy which applies to them. The policy is continuously reviewed against best practice and updated regularly in the light of regulatory and legislative changes. The Diversity Officers (see below) will notify the legal department if they become aware of any operational, regulatory or legislative change which may require a revision of the policy. All Co-Members have the opportunity to make suggestions regarding the diversity policy at any time and this will be encouraged. Diversity Officers Lawrence Carter, Director of HR, Learning & Development is Reed in Partnership's Diversity Officer and he reports to Chris Melvin, The Chief Executive of Reed in Partnership. As Diversity Officer he is responsible for the implementation of the Diversity Policy, for ensuring compliance with Diversity and Discrimination legislation, and operating a diversity strategy based on this policy within Reed in Partnership. Communications The initial chain of communication for Diversity issues is detailed above. A copy of this Diversity Policy will be available to all Co-Members on the intranet as part of the Co-Member Handbook. Any changes to the policy will be communicated to Co-Members by the most appropriate means, whether hard copy information sheets or soft copy such as e-mail. Department and Business Managers will be responsible for drawing the contents to the attention of their staff. Advice on Diversity issues may also be disseminated through Reed News, Reed’s weekly electronic newsletter. The relevant Diversity Officer or their nominated Diversity Administrator, normally located in your HR or People Department, will be available to answer queries on Diversity issues. The Diversity Officer has access to a number of additional technical and helpline resources including the Employers Forum on Disability Helpline. Reed and External Organisations Reed is and has been actively involved with a number of government, voluntary and academic institutions for the purposes of increasing our knowledge of Diversity, benchmarking practice and performance and promoting Diversity within Reed and more broadly in the labour market. Reed works with the Employers Forum on Disability on issues relating to disability, with the Institute of Public Policy Research on Racial Equality and Diversity in the Private Sector and with a number of organisations attached to the Department for Work and Pensions on age, gender, parenting and disability issues. Communications with statutory bodies such as the Commission for Equality and Human Rights are always conducted through the Legal Department in the first instance. Co-Members should not make representations to such organisations on behalf of Reed without the explicit authorisation of the Legal Department. Co-Member Surveys Reed has a regular programme of surveying Co-Members both on general issues of morale and specific employee relations topics. From time to time specific surveys are carried out of cross-sections of the workforce to examine Co-Member attitudes to diversity policies, practices and procedures. Employee survey data is also broken down by diversity statistics to examine differences in attitudes between different cross-sections of the workforce. Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 Monitoring Diversity monitoring is carried out both for the entire Reed family of companies and for each individual Operating Company. The objective of this monitoring is to ensure that: our procedures are fair to all groups; we identify and address any barriers to equality of opportunity, which could be unlawful; we are making best use of the full range of talents available within the community and within our existing workforce. our diversity policy is effective. our Co-Members reflect the local demographic to best support members. Reed collects and analyses the following data: whether and where people of each sex, from ethnic minority backgrounds and people with disabilities. are in Reed’s workforce and Candidate or Member base. whether there are differences in the pay rates of different groups. whether the likelihood of being selected for training, transfer or promotion is different for different groups. whether we provide accessible premises. whether people from one group are more likely than others to leave Reed’s employment. Much of this information is reported as part of the general Management Information Reporting that occurs. The Monitoring information is benchmarked at this stage against a variety of regional and national statistical databases. The data used for this monitoring derives from the HR files held electronically within the group. This information remains confidential at all stages. Individuals are never identified and monitoring data is produced in a statistical form only. Data held on HR files derives in some cases from Co-Members initial applications to Reed and in other cases from Confidential monitoring forms circulated by HR teams. This information is sensitive personal data and is treated as such as per the Data Protection Act 1998. Co-Members are not legally obligated to provide Reed with this information, however it is helpful for us if they do. Training Training and ongoing advice and instruction are delivered through staff induction programmes and other short courses, as well as Reed News. Business and Department Managers will be responsible for more site- or business specific Diversity training. Each Manager will ensure that each new Co-Member is made aware of the Diversity policy as part of their induction process Training on Discrimination Law forms an essential part of the formal Induction process of all Co-Members and all management training includes extensive training on good people management practices of which diversity awareness and diversity management form part. All our designer/deliverers both for internal and external courses are trained in disability awareness and the needs of disabled people in the training environment. Breach of the Policy Any apparent breach of the policy by a Co-Member will be dealt with through the Disciplinary Procedure. Proven discrimination will be treated as Gross Misconduct. Reed’s Grievance Procedure should be used if you believe that you may not have been treated equally in line with the policy. You will note that it first asks you to take up the matter with the individual against whom you have the grievance. However, you may also talk confidentially with someone from your HR team if the nature of your complaint makes the first course of action particularly difficult. Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 Reviewing the Policy Achieving diversity is an evolutionary process. It is necessary to review what we do regularly to keep pace with cultural change. If at any time any Diversity issue should arise which exposes a weakness in Reed’s Diversity Policy, the Policy will be subjected to review. The legal department will be responsible for the revision of this document; revisions will be made with the guidance of the Diversity Officer. If you have suggestions on how equality of opportunity might be improved within Reed, or in relation to the service provided to Employers, Members or other customers, you should use Reed’s suggestion scheme, ReedThink, to promote your ideas. Code of Practice An essential part of this policy is the Code of Practice which follows. Failure to abide by any article of the following Code of Practice will result in the application of the Disciplinary Policy as per 20.4.9 above. The following Code of Practice demonstrates how the Diversity policy is implemented. In many respects this goes beyond what the law requires and is based on best practice in recruitment and training. However Co-Members should not forget that if they break the law criminal prosecutions or civil claims may be brought against Reed and against them as an individual. Compliance with the law requires an understanding of the relevant statutes and regulations. Further guidance on applicable UK legislation is contained in Appendix 1 at the end of this Handbook. Co-Members, however, are not employed to act as legal advisors. If you are ever in any doubt about what to do, always refer to a higher level. Where Reed companies carry out functions of a public nature Reed will be compliant with the public sector equality duty set out in the Equality Act 2010. Company Commitments to Co-Members on Recruitment, Training and Development All recruitment and selection, whether internal or external, will be conducted on a non-discriminatory basis and monitored by your HR team. In so far as is reasonably practicable your HR team will ensure that a competency based and meritocratic approach is followed for the recruitment and selection of CoMembers. All internal vacancies whether for newly-created positions or existing positions becoming vacant will be advertised internally and applications invited on a nondiscriminatory basis. Our primary means of advertising vacancies both internal and external is via webbased systems (internet and/or intranet). We aim to ensure that our websites are accessible to those with visual impairments and HR teams will on request consider alternative forms of access where appropriate. All training and development activities will be planned and executed on a nondiscriminatory basis and will be made available to as many Co-Members as possible. All promotions will be made on a non-discriminatory basis and each HR team will ensure that in so far as is reasonably practicable a competency based and meritocratic approach is followed. No vacancies circulated to or from Co-Members will contain any directly or indirectly discriminatory statements. Training in non-discriminatory recruitment, selection and appraisal will be provided as widely as possible to Co-Members. All recruitment materials, including application forms, will be designed to eliminate discrimination and promote equality of opportunity. All such materials will also be available, on request, in alternative formats for Co-Members/ applicants with disabilities at the discretion of the relevant HR team. Appraisals are intended to form the basis of Co-Member career development and will be conducted to ensure equality of opportunity. Any ability or psychometric testing used in recruitment and selection will be free of bias. Tests will be benchmarked for adverse impact before introduction and will be monitored whilst in use to ensure that no adverse impact is evident. All testing materials will also be available, on request, in alternative formats for Co-Members/ applicants with disabilities at the discretion of the relevant HR team. Monitoring of recruitment, selection, promotion, remuneration and release will be undertaken by HR teams to assess the success of this policy. Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 All recruitment, selection and promotion meetings, events and interviews, whether external or internal, will upon request, be carried out at locations or offices accessible to those with disabilities. Further reasonable adjustments to facilitate recruitment whether internal or external will be made as necessary, following discussion with the applicant and the relevant HR team. Reasonable adjustments for Co-Members with disabilities will be made following discussions with the Co-Member concerned and the relevant HR team to ensure they are treated fairly. We will endeavour to provide appropriate workplace reintegration for those CoMembers becoming disabled whilst in our employ and will make appropriate and reasonable workplace adjustments to ensure that the Co-Member is able to continue working for Reed. This may entail job re-design, retraining, flexible working hours, and phased return to work. Co-Members and management should challenge inappropriate behaviours wherever they find them, either within the organisation or externally. In particular they should seek to challenge negative assumptions regarding the capacities of people with disabilities both within our organisation and in the wider labour market. Disabled people are as reliable and productive as any other employee group. Management Reviews, appraisals and board meetings will include discussion of diversity to assess the contribution of management teams to building a diverse workforce. Wherever practicable, property will be sourced that is fully accessible to disabled CoMembers, Members, Employers or Partners. Reed offers flexible retirement options for Co-Members. The Pension Scheme does not mean that you cannot retire earlier than your 65th Birthday and we will seek to accommodate flexible working practices both for those approaching the traditional retirement age and for those interested in continuing to work for us after that age. Wherever practicable, Reed will provide facilities, time and resources for religious observance during working hours. Reed will give priority to Co-Members religious festivals in the allocation of holiday leave. Company Commitments on Terms & Conditions of Employment Whilst these may be different for different Co-Members they will be designed to reflect the policy and to promote it. All terms & conditions of employment will be regularly reviewed to ensure their alignment with the policy. Wherever possible, working patterns will take account of caring commitments, and/or other requirements that may be related to a disability, pregnancy, religious observance or gender reassignment. The implementation of employment policies which are attractive to new parents will be given high priority. Managers’ and Supervisors’ Responsibilities All managers and supervisors are responsible for the day-to-day implementation of the policy including the Code of Practice. Professional advice should be sought from your HR team where necessary. Training of managers and supervisors to ensure their skills and knowledge encompass the principles and practices of diversity will be given high priority. Managers and any interested Co-Member with an employment and disability related question has access to the Employers Forum on Disability Helpline via the Diversity Officer for their company. Delivering services to Members and Employers All dealings with Members and Employers will be conducted in accordance with the Diversity policy, as well as the law, and will be monitored by your line management. Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 Taking Vacancies from Employers Where appropriate measures will be taken to bring this policy to the attention of employers. All job vacancies, temporary assignments and work trials from employers will be accepted and handled on a non-discriminatory basis only. Where this basis is in any doubt, or you have any suspicions that a client may think otherwise, line management should be informed immediately, prior to any further action being taken. There are limited situations in which discrimination is permitted. It is however unlikely that these will be applicable to any job handled by Reed and if a client claims a Genuine Occupational Requirement (GOR) 1 or other legal exception this should be referred to your line manager immediately for verification. If you are unsure as to why a client has specified a particular criteria which may appear discriminatory, a question such as: "Are you claiming a Genuine Occupational Requirement or other legal exception?" will help to establish the general situation. If the client maintains they have a GOR ask them to confirm the GOR in writing and seek advice from your Business Manager and HR Department. If no GOR. or Other Legal Exception is given, it is best to keep a friendly tone and say something like "I'm sure you wouldn't want me to break the law," or, "I can only accept such instructions if a valid Genuine Occupational Requirement or other legal exception exists". Explain to the Employer that you must put forward only the most suitably qualified Members for the job and the Employer must therefore amend the vacancy details to exclude the discriminatory instruction. If the employer insists that the instruction should stand, you should take no further action on the vacancy and inform the employer that you must refer the matter to your Business Manager. The Business Manager should attempt to resolve the matter but must refuse to work on the vacancy if the employer refuses to amend their instruction. The Business Manager must also make a written record of the occurrence. If we accept or act on discriminatory instructions we may be found guilty of aiding and abetting a discriminatory act. Before registering a vacancy genuinely covered by a GOR, Co-Members must seek advice/authority from your Business Manager and HR Department who must ensure: that the GOR or other legal exception exists in law; that the employer has taken reasonable steps to ascertain that no other working arrangement is possible; that the employer is prepared to give us written authority stating the facts; and that we take advice from the Legal Department as to whether the information obtained constitutes a reasonable enquiry on our part, and a reasonable defence on the employer's part. Where unlawful discrimination is suspected, at any stage in the recruitment process, Line Management, strictly in consultation with the HR team, will be responsible for informing the Employer that discrimination is unlawful. HR teams will record such instances. It is important that the employer should understand that you cannot, and will not, accept a discriminatory instruction. For the sake of an easy life some recruitment organisations and welfare to work providers have, in the past, accepted such instructions, intending not to work on filling the job. That defence has always sounded rather implausible when the employer turned out to be a journalist engaged on a mystery shopper exercise. The Department for Business, Innovation & Skills also regularly undertake such exercises, so it is important to remain vigilant. The DBIS ultimately have the power to prevent a recruitment agency or welfare to work provider from trading. In addition to the above Co-Members will specifically refuse to act on indirectly discriminatory instructions from employers - i.e. that requirements or conditions should be applied that would have a disproportionately adverse effect on applicants of a particular group and which cannot be shown to be justifiable. Employers will normally agree to change such requirements and will in most cases have been genuinely unaware that they were discriminatory. Some will need to demonstrate to your line manager that they are justified and some will harden their stance into one of direct discrimination, in which case the process outlined above should be followed. Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 Common examples of indirectly discriminatory items are below: Excessive Language Requirements/Accents/Clear Voice. Watch out for criteria such as "Excellent English required", where the job seems unlikely to require such a high standard of English. Dress Restrictions. Overly-prescriptive dress codes may disadvantage followers of some religions. Muslim women, for example, may be obliged by their religion to wear trousers and would not be able to comply with a dress code that forbade trousers. Geographical Boundaries. For example, "Applicants will be considered from Bromley but not Lewisham". This may have the effect of excluding certain racial groups who live in certain areas of a city. Excessive qualification levels/insistence on qualifications obtainable only in one Country A qualifications criteria that is excessively high for the job may discriminate against certain groups. Also, those schooled outside the UK, for example, are unlikely to have GCE qualifications. Specific qualification requirements. Specifying that a candidate must have A Levels or GCSE’s may discriminate against certain age groups and those educated outside of the UK. Work History. An instruction such as "must have spent six of the last twelve months as a Credit Controller" indirectly discriminates against recent mothers looking to return to work, for example, because of the reference to a particular point in time. Note, on the other hand, that "must have six months' experience" is not discriminatory since it does not specify when that experience should have been gained. An instruction that the applicant must have 10 years experience of credit control or for an accountant with 5 years post qualification experience will be discriminatory on the grounds of age. Job Title. "Warehouseman", "Manageress", “Postman”. Where such job titles are used, a clear statement that applications from all genders is required. It is however best practice to avoid them. Location/Accommodation. For instance: "Must live-in, single accommodation only". This disproportionately affects married applicants. Height. For example: "Must be over 5' 10". This would affect women more than men. Thus, unless the job required a particular height to operate machinery, or for some similar reason, it would be discriminatory. NB - some organisations such as the Police and Prison Service are allowed to set height requirements. Qualification Types. For example: "Must have Woodwork 'O' level or equivalent" would discriminate against women; just as "must have Domestic Science 'O' level or equivalent", would discriminate against men. Thus, unless these qualifications were essential for the job they may be deemed illegal. Must touch type. This does not explain why touch-typing is essential and may exclude a capable Member with Repetitive Strain Injury. This could be replaced with “you will need to produce high quality reports using a word processing package at regular intervals and at short notice”. This will allow an applicant with RSI to demonstrate their ability to meet the criteria using voice-activated software. Must Have a Driving Licence. This does not explain why a driving license is essential, and may exclude a Member with a visual impairment or arthritis who cannot drive. Replace with “extensive travel throughout the UK to meet clients is essential”. The Member may be able to demonstrate how they will meet this requirement by using alternative methods of transport. Presenting Members to Employers Co-Members should not draw attention to or discuss a Member’s race, religion or beliefs when recommending applicants unless the employer is trying to attract applicants of a particular racial group under the exceptions in the Equality Act 2010. Wherever possible, Co-Members should not draw attention to or discuss a Member’s sex. Try to ensure neutrality by talking about "our Member" and omitting names. If an Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 employer asks you directly about marital or civil partnership status, pregnancy or dependants, you must reply: "I'm sorry, I am not allowed to divulge that information. You should not disclose a Member’s age or date of birth to an employer You should not take ageist instructions, whether directly or indirectly discriminatory, from an employer. Where a disabled person has requested a reasonable adjustment to an employer’s normal recruitment process we should bring this to the attention of the employer. As we are in no position to ascertain what adjustments (if any) may be required to undertake the day-to-day activities of any particular job, we must not enter into discussion on these matters with either the Member or the employer. This can be resolved only between the Member and the employer during interview. All pre-selection methods will reflect the policy. When carrying out shortlisting or preselection Co-Members should bear in mind that if a Member appears overqualified there could be a legitimate reason relating to previous labour market disadvantage for an individual changing career or seeming to backtrack. Periods of inactivity may for example be directly related to a disability or caring commitments. No Co-Members must make remarks, either verbal or written, which could result in direct or indirect discrimination. In particular Co-Members should be aware of the effect which generalised assumptions, stereotypes and prejudices can have on their treatment of members of particular groups, (for example gender stereotyping, assumptions about ability based on race, or on working practices based on religion) and should seek to avoid forming views on Members abilities based on anything other than demonstrated skills attributes and qualifications for the role in question. Member Registration, Contacts and Complaints If a Member alleges discrimination by Employers or colleagues, complaints of this nature must always be brought to the attention of your Business Manager. Under no circumstances should you take sides or offer advice. If a Member asks us to reveal information to an employer that might be considered likely to aid or abet discrimination (e.g. a devout Muslim), we should decline to do so and advise the Member to inform the employer personally if they so wish. The registration process for Members will however specifically seek to establish whether there are any health-related barriers to work for that Member and will directly ask such questions. However it should be made clear during registration that such information will not be directly passed on to an employer without this previously having been discussed with the Member. Prior to a job offer, only information regarding adjustments required to attend interview should be communicated to the employer with the Member's permission. Other health or disability related details should only be passed to the employer with the Member's permission subsequent to a job offer (conditional or unconditional). Information on branch and office accessibility is available by contacting the branch or office. In the rare circumstances where a branch is not fully accessible it will be possible to arrange a meeting at the Member’s convenience at a nearby Reed location or other suitable accessible location. All application, registration and testing materials, are available in alternative formats upon request. Should you receive such a request please contact your HR team who will organise this. Testing may prove complex in such cases and Members should be asked whether the test itself will prove problematic as a result of any disability. Members whether they have a visible disability or not should be asked whether adjustments are necessary to enable them to compete fairly in any recruitment process. This question should be asked as part of the registration process for all Members, however you may find it useful to enquire earlier if a Member is arranging a time to register. Co-Members should avoid asking particular Members (and not others), on the basis of visible health impairments, whether they have a disability or not, or enquiring into the nature of that disability. Such selective questioning is likely to lead to accusations of discrimination. When dealing with Members, Co-Members from Reed in Partnership may well find it beneficial to ask direct questions regarding a Member’s disability (once they have declared this to you), however this is for the purposes of establishing whether this Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 may be a barrier to work, and questions that do not relate to how their disability impacts upon their ability to work should be avoided. Currently IT systems include a question asking date of birth in a mandatory field. You should continue to ask for and complete this information on the system. If a Member queries why you are asking their date of birth you should explain that the information is required under the Eligibility to work legislation and the Conduct of Employment Agencies and Employment Business Regulations. You should make it clear to the Member that this information is not forwarded to employers and Reed does not discriminate in any way in the provision of its services. Many deaf people prefer to use sign language. It is a language like any other, with its own grammar. Interpreters should be provided if deaf people are present at meetings or in an official interview situation. Find out if you need BSL (British Sign Language) or SSE (Signed Supported English) interpreters. You should allow at least three weeks to book such an interpreter through partner organisations, and/or a text phone if the Member requests one, as both these items can be difficult to get hold of at short notice. You should make it clear to the Member that they will not have to pay for this service. Co-Members should respect Members membership of faith communities. This does not mean that you are expected to know what may or may not be permitted in certain religions. However if a Member informs you that their membership of a particular religion or faith may impact upon their day to day work you should make a note of this as part of the registration process. Co-Members should respect Members sexual orientation. The sexual orientation of Members should not be discussed with Employers. . Advertising All advertising, including window cards, leaflets, printouts, free standing or wall mounted displays and adverts, both online and in printed media (newspapers, magazines etc), whether written by Reed or an employer, (including client paid advertising), should not include any wording or images that suggest, explicitly or implicitly, that applications from any particular group, including age groups will not be considered or will be treated more or less favourably than others. The only exception is where a GOR applies and this has been established correctly as per the above guidelines, or for purposes of positive action, i.e. to encourage applicants with protected characteristics in order to improve diversity This approach to advertising applies to all age groups including young and old. Advertisements should not include phrases or images that might perpetuate a stereotypical view of suitability for a role. We will seek to ensure a creative approach to our advertising that reaches a wide and diverse pool of Members. Avoid the use of words or phrases that are designed to appeal to a particular age group such as; Young, Dynamic, Energetic, Flexible, Fast moving market place, In touch with the latest thinking, Have boardroom gravitas and presence, Mature, Young company. Other phrases such as junior, senior and experienced should only be used if they are a recognised term in the relevant industry and can be objectively justified. Similarly avoid images and pictures in advertisements or Company literature, or the selection of publications/media that may appear to favour, appeal to, or be largely read by a particular age group, gender, ethnicity, nationality, sexual orientation, religion or belief, or exclude disabled persons. For instance a picture of a group of twenty-year olds may discourage older workers and be potentially discriminatory. The exception to this is where we are advertising to seek registration on to a programme and the programme is specifically contractually targeted at a particular group. Requirements for certain qualifications may be discriminatory, for example a requirement for 10 GCSE’s could suggest that anyone above the age of 35 would be precluded from applying. Instead use phrases that make clear other factors will be considered such as “GCSE’s or equivalent”, “graduate or equivalent”, “ideally but not necessarily” and “pleased to receive applications from outstanding candidates”. Extracted from the Reed in Partnership Co-Member Hand book Reed in Partnership – Skills v2 June 2011 Do not set maximum or minimum amounts of experience in advertisements or role profiles. For example the phrases such as, “4 years managerial experience is essential” or, “must have 2 to 4 years post qualification experience”, will not be acceptable requirements unless they can be objectively justified. Instead focus on the skills required. For example “the candidate must be able to demonstrate how their experience is relevant at interview”, and “the successful candidate will have demonstrable leadership skills”. By placing limits on the experience without objective justification you can discourage older applicants with more experience who may still wish to apply and younger applicants who may be suitable for the role but have not yet obtained the requisite experience. Focus on the essential skills and aptitudes required for the post, not what is desirable. Use inclusive language in advertising. For example “any other exceptional candidates will be considered”. Make clear that qualifications which are equivalent or similar to those you are requesting will be acceptable, or be ready to justify your insistence on those qualifications. Ask yourself; are the qualifications necessary? Are they still current? And, are there other ways of specifying the skills you require? Delivering training, development and group work to Members This section of the Code of Practice applies to all Reed in Partnership programmes as all are subject to Ofsted inspection. Ofsted regard all of our programmes as operating a publicly funded training service to Members. Following this section of the Code of Practice ensures compliance with the Special Educational Needs and Disability Act 2001 (SENDA). Where appropriate measures will be taken to bring this policy to the attention of any partners involved in the design and delivery of courses or other programmes of training. This may include associate trainers, employers or employer organisations on whose behalf we are designing courses, funding organisations and any other individuals involved in the design and delivery of courses or programmes of training. All design and delivery of courses or other programmes of training should take place without any potential trainees being treated less favourably than anyone else. Where this is in any doubt, or you have any suspicions line management should be informed immediately, prior to any further action being taken. Advertising or promotion of any course or programme of training will be carried out in such a way that it encourages applications and interest from all individuals. All entry on to courses shall be carried out with reference to disability information disclosed by proposed trainees or applicants, where they have permitted this information to be used in this way. This is in order to monitor and ensure that the provisions of SENDA can be applied. However reference to no other sensitive personal data (e.g. ethnic background) is allowed. Voluntary disclosure of disability information will therefore be provided for in any data capture forms required in order to commence a particular course of training and may be confidentially discussed by the trainer and individual in order to support the provision of necessary reasonable adjustments. Reasonable adjustments will be offered in consultation with the individuals concerned for both the assessment process for entry on to the course or programme of training and the programme or course itself. Reasonable adjustments could include, but are not limited to: changes to course requirements or work placements, changes to physical features of premises, the provision of interpreters or other support workers, the delivery of courses in alternative ways, or the provision of materials in other formats. Extracted from the Reed in Partnership Co-Member Hand book