Equality, Diversity and Inclusion Policy

Introduction

This policy sets out our commitment to ensuring that all employees and job applicants have equal opportunities, whether in terms of our background, personal characteristics, experience, skills, or motivations.

Fostering an inclusive culture helps each of us benefit from a wider range of these different perspectives, experiences, and skills. We believe that this creates a happier, more productive working environment for us all.

To support this culture this document sets out our policy on equality, diversity, and inclusion, in particular:

  • outlines our commitment throughout the employment lifecycle to equality, diversity and inclusion and sets out how we put this commitment into practice;
  • what we regard as acceptable behaviour at work and what is not acceptable;
  • the rights and responsibilities of those to whom the policy applies;
  • sets out the steps we take to make our culture as inclusive as possible;
  • the procedure for dealing with concerns or complaints;
  • how we will deal with any breach of this policy;
  • who is responsible for the policy; and
  • how it will be implemented, monitored, and

This policy does not form part of your contract of employment, and we reserve the right to amend or withdraw it at any time.

Scope

This policy applies to employees, staff, temporary and agency workers, interns, volunteers, apprentices, job applicants, and contractors. All employees are responsible for ensuring that there is no discrimination in the workplace, as outlined in the policy statement, and for ensuring that this policy is applied on a day-to-day basis. They are also expected to apply the principles of equal opportunities and non-discrimination in their interactions with clients/customers, suppliers, business partners, and visitors. In certain circumstances, an employee can be personally liable for discrimination against a fellow employee or a job applicant.

The policy accompanies our Harassment and Bullying Policy, Menopause Policy, and any other Equality, Diversity, and Inclusion (EDI) policies adopted by us.

 

Policy Statement

We are committed to providing equal opportunities to all who work for us, promoting a working environment based on equality, diversity, inclusion, dignity, trust, and respect, and one that is free from discrimination, harassment, bullying, or victimisation, and eliminating unlawful and unfair discrimination.

We aim to create a culture that encourages and values diversity and inclusion and that appoints, rewards, and promotes employees based on merit.

We ensure that our recruitment, promotion, and retention procedures do not treat people less favourably because of:

  • age;
  • disability;
  • gender reassignment;
  • marriage or civil partnership status;
  • pregnancy and maternity;
  • race (including colour, nationality, and ethnic or national origin);
  • religion or belief;
  • sex;
  • sexual orientation;
  • part-time status;
  • fixed-term status;
  • trade union membership (or non-membership);
  • socio-economic background; or
  • caring

 

What We Expect From You

We expect you and every one of our employees to take personal responsibility for observing, upholding, promoting, and applying this policy. Our culture is made in the day- to-day working interactions between us, so creating the right environment is a responsibility that we all share.

Cultivating this culture does not happen by accident but requires ongoing commitment and nurturing. The reality is that we live in a world where areas of difference (whether gender, sexual orientation, ethnicity, or others) often translate to biases, challenges, and barriers that may not be faced by others. The more areas of difference a person brings, the more this effect can be compounded. In this way, the experiences of a black woman with a disability may be very different from the experiences of a black woman without a disability and also very different from the experiences of a white woman. This way of looking at diversity and inclusion is known as “intersectionality”. Intersectionality examines how a person’s identities, such as their gender, ethnicity, and sexuality, affect their access to opportunities and privileges.

We expect you to treat your colleagues and third parties (including clients/customers, suppliers, contractors, agency staff, and consultants) fairly and with dignity, trust, and respect. Sometimes, this may mean allowing for different views and viewpoints and making space for others to contribute.

By embedding such values and constructively challenging inappropriate comments or ways of working, you can help us achieve and maintain a truly inclusive workplace culture. Any dealings that you have with colleagues or third parties must be free from any form of discrimination, harassment, victimisation, or bullying.

If any of our employees are found to have committed, authorised, or condoned an act of discrimination, harassment, victimisation, or bullying, we will take action against them, including those to whom it applies, under our disciplinary procedure.

You should be aware that you can be personally liable for discrimination and harassment.

 

Equality Principles and Implementation

As set out in the policy statement, there should be no discrimination because of any of the protected characteristics or other factors. The types of discrimination that are prohibited are explained below. Discrimination may occur in the following forms:

Direct Discrimination

Treating someone less favourably because of a protected characteristic compared with someone who does not have that characteristic, for example, choosing not to recruit someone because they are disabled and you think they ‘would not fit in’ to the team.

Indirect Discrimination

Where a policy, procedure, or way of working that applies to everyone puts people with a particular protected characteristic at a disadvantage compared with people who do not have that characteristic, unless there is a good reason to justify it. An example is a dress- code policy that prohibits headgear, which could affect women who wear headscarves for religious or cultural reasons.

Associative Discrimination

Treating someone less favourably because they are associated with someone who has a protected characteristic, for example, because their partner is transgender.

Discrimination by Perception

Treating someone less favourably because you perceive them to have a protected characteristic even if they do not, for example, choosing not to promote someone because you mistakenly perceive them to be gay.

Discrimination Arising From Disability

This is unfavourable treatment of the disabled person because of something arising in consequence of their disability. Such treatment is unlawful unless it can be objectively justified. Examples include:

  • dismissing or failing to pay a bonus to someone because of their disability-related absence; or
  • disciplining someone for losing their temper where such loss of temper was out of character and was due to severe pain caused by them having cancer.

Failing to Make Reasonable Adjustments (in the case of disability only)

We are legally obliged to make reasonable adjustments to ensure that aspects of employment or our premises do not put a disabled person at a substantial disadvantage. Failing to comply with this duty is unlawful. This duty comprises three requirements, each of which arises where a disabled person is at a substantial disadvantage in relation to a ‘relevant matter’:

  • The first is a requirement, where a provision, criterion, or practice puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to avoid the disadvantage.

 

  • The second is a requirement, where a physical feature puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to avoid the disadvantage.

 

  • The third is a requirement, where a disabled person would, but for the provision of an auxiliary aid, be put at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to provide the auxiliary aid.

 

Examples of reasonable adjustments might include:

  • allocating some of the disabled person’s duties to a colleague;
  • changing their working hours or place of work;
  • adjusting procedures for assessing job candidates; and
  • modifying disciplinary and grievance

 

Victimisation

This is treating someone less favourably because they have alleged discrimination or asserted their right not to be discriminated against because of a protected characteristic. An example of this would be an employee claiming that they had been discriminated against, who is then refused a reference by their manager because of that claim.

 

Harassment and Sexual Harassment

Harassment is unwanted conduct related to a protected characteristic that has the purpose or effect of:

  • violating someone else’s dignity; or
  • creating an intimidating, hostile, degrading, humiliating, or offensive environment for someone else.

Sexual harassment is:

  • conduct of a sexual nature that has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment; and
  • less favourable treatment related to sex or gender reassignment that occurs because of a rejection of, or submission to, sexual

 

Bullying

There is no legal definition of bullying. However, we regard it as conduct that is offensive, intimidating, malicious, insulting, or an abuse or misuse of power, and usually persistent, that has the effect of undermining, humiliating or injuring the recipient.

Bullying can be physical, verbal, or non-verbal conduct. It is not necessarily face to face and can be done by email, phone calls, online, or on social media. Bullying may occur at work or outside of work.

If the bullying relates to a person’s protected characteristic, it may also constitute harassment and, therefore, will be unlawful.

You should refer to our Harassment and Bullying Policy for further information on our procedure for reporting harassment and bullying.

 

Equality of Opportunity

 

Recruitment

We take reasonable and appropriate steps to encourage job applications from as diverse a range of people as possible.

Anyone making a decision about recruitment must not discriminate in any way and must have attended appropriate diversity and inclusion training.

Every decision-maker should challenge themselves and other members of the recruitment selection panel to make sure that any stereotypes, unconscious bias, or prejudice do not play any part in recruitment decisions.

Career Development

Any decision we make relating to a person’s promotion or career development will be free from discrimination.

We ensure that selection criteria and processes for recruitment and promotion are reviewed on a regular basis so that there is no discriminatory impact on a certain group.

Disability Inclusion

Recruiting People With a Disability

Employees involved in recruitment will consider disability in advance of a recruitment campaign so that advertising, application forms and assessments, arrangements for interviews, job descriptions and employee specifications, and selection criteria are appropriate and as inclusive as possible.

We will ask applicants at the outset if they require any reasonable adjustments to be made to the recruitment process. These may include ensuring easy access to the premises for an interview, adapting psychometric tests, replacing psychometric tests with an alternative option, providing an alternative to a telephone interview for a deaf candidate, and/or providing a suitable chair for an interview with a candidate suffering from back problems.

If you are involved in the interview process, you must not ask job applicants about their health or disability.

 

Talking About Disability

We understand that some people find it hard to discuss their disabilities and that disability can be invisible.

Psychological safety, where people feel able to speak up about their experiences without fear of negative consequences, is paramount to ensuring disability inclusion.

However, this is only possible if we treat people with dignity, trust, and respect, and we expect everyone to uphold these values.

We do not tolerate discriminatory or socially prejudiced (ableist) language in our organisation. This type of language is negative, inappropriate, or offensive towards people with a disability and may take the form of jokes or “banter”. If you adopt such language, we will take action against you, including, for those to whom it applies, under our disciplinary procedure.

 

Reasonable Adjustments

If you have a disability, you do not have to tell us. However, we would encourage you to let us know so that we can support you, for example, by making reasonable adjustments to our premises, aspects of your role, or our working practices.

If you are experiencing difficulties at work because of your disability, please contact your line manager to discuss potential reasonable adjustments that may alleviate or minimise such difficulties. We may need to discuss your needs with you and your medical adviser to help us get the right support in place.

For employees who are returning from long-term disability-related absence, we have a return to work support programme in place. For further information, please contact your line manager.

Support

If you have a disability or you care for someone with a disability and need emotional support or help with practical issues, please contact our Employee Assistance Programme (EAP) or a supervisor for confidential advice.

Accessibility

If you experience accessibility issues due to your disability, for example, because of aspects of our premises or because you do not have adaptive equipment to help you perform your role, please contact your line manager.

Neurodiversity

Neurodiversity describes differences in brain function from person to person that affect daily mental functions. Neurodiversity encompasses a wide range of conditions, including autism, ADHD, dyslexia, dyspraxia, and more. Whether neurodiversity should be considered a disability depends on the context and perspective. So a neurodivergent person may have to be considered under the above heading of ‘Disability Inclusion’ and we may therefore have a duty under the Equality Act.

We are committed to developing a neurodiverse inclusive workplace (neuroinclusion) to encompass employees or potential employees that are neurodivergent.

 

Training

If you are involved with making decisions about a person’s employment, you must attend appropriate equality, diversity, and inclusion training.

All new starters must attend equality, diversity, and inclusion training as part of their onboarding programme.

 

Monitoring and Review

We analyse diversity and inclusion data, in compliance with our data protection obligations, on an ongoing basis to assess the impact of this policy and our equality, diversity, and inclusion strategy.

The principles set out in this policy apply in the workplace and outside the workplace in a work-related context, such as on business trips, customer or supplier events, or work- related social events, and at any time while you are wearing a work uniform.

Special responsibility for the practical application of this policy falls upon managers and supervisors involved in the recruitment, selection, appraisal, promotion, and training of employees and the way their terms of employment are fixed.

Senior management is responsible for this policy, its implementation, monitoring, and review.

 

Process for Unfair Treatment

Procedure for Dealing With Concerns

If you have any doubt or concern about this policy or how it should be applied in any particular instance or situation, please contact a supervisor as soon as possible.

If you believe you have been unfairly treated in breach of this policy, you should follow our grievance procedure. The harassment complaints procedure set out in our Harassment and Bullying Policy is also available if you believe that you may have been harassed or bullied. You will not be victimised in any way for making such a complaint in good faith. Complaints of this nature will be dealt with seriously, in confidence, and as soon as possible.

How We Will Deal With a Breach of This Policy

We will not tolerate behaviour that goes against this policy, and where you are alleged to have breached this policy, you will be subject to our disciplinary procedure. Disciplinary action will be taken if you are found to have breached this policy. Serious breaches of this policy, acts of unlawful discrimination, and serious incidents of harassment and bullying will be treated as gross misconduct.

Unwarranted allegations that are not made in good faith may also be considered a disciplinary matter.