Equal Opportunities Policy Statement
The Company opposes discrimination against and/or harassment of anyone because of their race, ethnic or national origin, gender, sexual orientation, gender reassignment, marital or civil partner status, pregnancy or maternity, disability, class, age, religion or belief (Protected Characteristics). In
addition the company will not discriminate based on trade union membership.
This policy covers all individuals working at the Company at all levels and grades, including senior managers, officers, directors, employees, consultants, contractors, homeworkers, part-time and fixed-term employees, casual workers and agency staff (collectively referred to as Staff).
All Staff have a duty to act in accordance with this policy, and therefore to treat colleagues with dignity at all times, and not to discriminate against or harass other members of Staff, whether junior or senior to them. In some situations, the Company may be at risk of being held responsible for the
acts of individual members of Staff and will not therefore tolerate any discriminatory practices or behaviour.
Furthermore, we will not tolerate any discriminatory practices or behaviour by our visitors, clients,
customers and suppliers towards our workforce.
Responsibility for the Policy
The Board has overall responsibility for the effective operation of the Company’s equal opportunities policy and for ensuring compliance with the relevant statutory framework prohibiting discrimination. All members of Staff are responsible for the success of this policy and must ensure that they
familiarise themselves with the policy and act in accordance with its aims and objectives.
Forms of discrimination
Discrimination by or against an employee is generally prohibited unless there is a specific legal exemption. Discrimination may be direct or indirect and it may occur intentionally or unintentionally.
Direct discrimination
Occurs where someone is treated less favourably because of one or more of the Protected Characteristics set out above. For example, rejecting an applicant on the grounds of their race because they would not "fit in" would be direct discrimination.
Direct discrimination can be based upon the fact that the person has a Protected Characteristic, is perceived to have a Protected Characteristic or because they associate with someone who has a Protected Characteristic.
Indirect discrimination
Occurs where someone is disadvantaged by an unjustified provision, criterion or practice that also puts other people with the same protected characteristic at a particular disadvantage. For example, a requirement to be over a particular height may put women at a particular disadvantage because they are generally shorter than men. Such a requirement will need to be objectively justified.
Harassment
Harassment related to any of the protected characteristics is prohibited. Harassment is unwanted conduct that has the purpose or effect of violating someone's dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.
Recruitment and selection
The Company aims to ensure that no job applicant suffers discrimination because of any of the Protected Characteristics. Recruitment procedures will be reviewed regularly to ensure that individuals are treated on the basis of their relevant merits and abilities. Job selection criteria are regularly reviewed to ensure that they are relevant to the job and are not disproportionate.
Job advertisements should avoid stereotyping or using wording that may discourage groups with a particular Protected Characteristic from applying.
The Company shall take steps to ensure that vacancies are advertised to a diverse labour market reaches a wide labour market and, where relevant, to particular groups that have been identified as disadvantaged or under-represented in the Company.
Applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with senior manager approval. For example:
Questions necessary to establish if an applicant can perform an intrinsic part of the job
(subject to any reasonable adjustments)Questions to establish if an applicant is fit to attend an assessment or any reasonable
adjustments that may be needed at interview or assessment.Equal opportunities monitoring (which will not form part of the decision-making process.)
Applicants should not be asked about past or current pregnancy or future intentions related to
pregnancy. Applicants should not be asked about matters concerning their Protected Characteristics without the approval of senior manager (who should first consider whether such matters are relevant and may lawfully be taken into account).
The Company is required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from a Senior Manager or the UK Border Agency.
To ensure that this policy is operating effectively, the Company may monitor applicants' racial origins, gender, disability, sexual orientation, religion and age as part of the recruitment procedure. We may also maintain records of this data solely for the purposes stated in this policy. Ongoing monitoring and regular analysis of the data provide the basis for taking appropriate positive steps to
eliminate unlawful direct and indirect discrimination and implement this policy.
Staff training, promotions and conditions of service
Staff training needs will be identified through regular staff appraisals. All workers will be given an equal opportunity and access to training to enable them to progress within the Company. All promotion decisions will be made on the basis of merit.
The composition and movement of workers at different levels will be regularly monitored to ensure equality of opportunity at all levels of the organisation. Where appropriate, steps will be taken to identify and remove unnecessary or unjustifiable barriers and to provide appropriate facilities and
conditions of service to meet the special needs of disadvantaged or under-represented groups.
Our conditions of service, benefits and facilities will be reviewed regularly to ensure that they are available to all workers who should have access to them and that there are no unlawful obstacles to accessing them.
Termination of employment
The Company will monitor redundancy criteria and procedures to ensure that they are fair and objective and do not directly or indirectly discriminate against employees.
The Company will also ensure that disciplinary procedures are carried out fairly and uniformly for all workers, whether they result in the giving of disciplinary warnings, dismissal or other disciplinary action.
Disability discrimination
If an Employee is disabled or becomes disabled in the course of their employment with the Company, they are encouraged to tellthe Company about their condition. This is to enable the Company to support them as appropriate.
The Employee may also wish to advise their manager of any reasonable adjustments to their working conditions or the duties of their job which they consider to be necessary, or which would assist the Employee in the performance of their duties. The Employee’s manager may wish to consult with the
Employee and with their medical adviser(s) about possible reasonable adjustments. Careful consideration will be given to any such proposals and they will be accommodated where possible and proportionate to the needs of the Employee’s job. If the Company considers a particular adjustment would not be reasonable we will explain our reasons and try to find an alternative solution where possible.
The Company will monitor the physical features of its premises to consider whether they place disabled Staff members, job applicants or service users at a substantial disadvantage compared to other Staff members. Where possible and proportionate, The Company will take steps to improve access for disabled Staff members and service users.
Breaches of the policy
If an Employee believes that they may have been discriminated against on any of the unlawful grounds listed above, they are encouraged to raise the matter through the Company’s grievance procedure. If a member of Staff believes that they have been subject to harassment on any of the unlawful grounds, they are encouraged to raise the matter through our anti-harassment and bullying policy.
Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure. Staff who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations of a breach in this policy which are
found to have been made in bad faith will, however, be dealt with under our disciplinary procedure.
If, after investigation, a member of staff is proven to have committed an act of discrimination or harassment, they will be subject to disciplinary action. In serious cases, such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. The Company will always take a strict approach to serious breaches of this policy.
Monitoring and revision of policy
The Company will regularly monitor the effectiveness of this policy to ensure it is achieving its stated objectives by monitoring the composition of job applicants and the benefits and career progression of its workers, so far as possible. The Company is committed to providing relevant training for all staff on their responsibilities and duties under this policy.
