Equal Opportunities

Introduction

The Company recognises the contribution made by all colleagues, regardless of gender, sexual orientation, marital or civil partner status, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability or age (the "protected characteristics").

The Company will aim to ensure that colleagues are able to work an environment that is free from discrimination and harassment, and will not tolerate any discriminatory practices or behaviour. The Company will recruit, promote, train and dismiss colleagues solely on the basis of merit and behaviour.

This policy applies to all colleagues of the Company working in the UK. It applies equally to the treatment of our visitors, clients, customers and suppliers by colleagues and the treatment of colleagues by these third parties.

Forms of discimination

Discrimination may be direct or indirect and it may occur intentionally or unintentionally.

Direct discrimination occurs where someone is put at a disadvantage because of one or more of their protected characteristics. For example, rejecting an applicant on the grounds of their race because it is considered they would not "fit in" could be direct discrimination.

Indirect discrimination occurs where an individual is subject to a provision, criterion or practice which puts them at a particular disadvantage because of, for example, their sex or race. For example, a requirement that all colleagues work full time could be indirectly discriminatory. If this practice cannot be objectively justified for a reason unconnected with sex, it would be indirectly discriminatory.

Discrimination also includes victimisation (less favourable treatment because of action taken to assert legal rights against discrimination or to assist a colleague in that regard) and harassment (engaging in conduct which violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive atmosphere).

Discrimination can also occur where a colleague does not actually have the characteristic in question, but is perceived to do so. For example, if someone assumed that a colleague was homosexual and harassed them on this basis, this would still be discrimination even if the colleague was not actually gay.

It is also unlawful to discriminate against someone of the grounds of a protected characteristic held by someone with whom they associate. As an illustration of this, if a colleague was treated less favourably because they had a disabled child, this could be discrimination.

Recruitment and selection

The Company will aim to ensure that no job applicant receives less favourable treatment on the grounds of any protected characteristic. Job selection criteria will be regularly reviewed to ensure that they are essential for the effective performance of the job and therefore justified on non-discriminatory grounds.

The Company will not ask questions about an applicant’s health prior to making an offer of employment, unless the aim is to find out whether an applicant requires any assistance with the application process. The only exception to this will be where the Company needs to establish whether the applicant will be able to carry out a fundamental and intrinsic function of the job.

Staff training and promotion and conditions of service

All colleagues will be given appropriate access to training to enable them to progress within the organisation and all promotion decisions will be made on the basis of merit.

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 underrepresented groups.

Termination of employment

The Company will monitor redundancy criteria and procedures to ensure that they are fair and objective and are not directly or indirectly discriminatory.

The Company will also ensure that disciplinary procedures are carried out fairly and uniformly for all colleagues, whether they result in the giving of disciplinary warnings, dismissal or other disciplinary action.

Disability discrimination

Colleagues who are disabled, or become disabled in the course of their employment with the Company are encouraged to tell us about their condition. This is to enable us to support them as much as possible. Colleagues may also wish to advise their line manager or the People Team of any reasonable adjustments which could be made to their working conditions or the duties of their job which would assist in the performance of their duties.

Colleagues and line managers should note that the definition of disability for the purposes of discrimination legislation is very wide. It encompasses all physical and mental impairments which have a substantial and long term adverse effect on a colleague’s ability to carry out normal day to day activities. Depending on the circumstances this may well include conditions which are not normally thought of as disabilities, such as depression and repetitive strain injury.

Your line manager or the People Team may wish to consult with you and with your medical adviser 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 your job. Nevertheless, there may be circumstances where it will not be reasonable for us to accommodate suggested adjustments and we will ensure that we provide you with information as to the basis of our decision not to make any adjustments.

We will monitor the physical features of our premises to consider whether they place disabled workers or job applicants at a substantial disadvantage compared to other staff. Where possible and proportionate, we will take steps to improve access for disabled staff and service users.

Fixed-term colleagues

We monitor our use of fixed-term colleagues, and their conditions of service, to ensure that they are being offered appropriate access to benefits, training, promotion and permanent employment opportunities. We will, where relevant, monitor their progress to ensure that they are accessing permanent vacancies.

Part-time workers

The Company will monitor the conditions of service of part-time colleagues and their progression to ensure that they are being offered appropriate access to benefits and training and promotion opportunities. The Company will ensure requests to alter working hours are dealt with appropriately under our Flexible Working for Parents, Guardians and Carers policy.

Breaches of the policy

If you believe that you may have been discriminated against you are encouraged to raise the matter through our Grievance and Whistleblowing Policy. If you need advice on how to proceed you should speak to the People Team.

Allegations regarding potential breaches of this policy will be treated in confidence and investigated promptly in accordance with the relevant procedure. Colleagues who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations which are found to have been made in bad faith will, however, be dealt with under our Disciplinary Policy.

Any colleague who is found to have committed acts of discrimination or harassment will be subject to disciplinary action. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. We always take a strict approach to serious breaches of this policy.

Roles & responsibilities

All colleagues 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.

Those working at a management level have a specific responsibility to set an appropriate standard of behaviour, to lead by example and to ensure that those they manage adhere to the policy and promote our aims and objectives with regard to equal opportunities.

Line managers' responsibilities

Recruitment

Review all job selection criteria to ensure that they are essential for the proper performance of the job;
Not to disregard qualifications awarded by non-UK institutions;
To avoid stereotypes, and not to assume that certain jobs are suitable only for men or women;
When interviewing, to avoid asking personal questions unrelated to the requirement of the job (such as questions about family circumstances).

General

To ensure that all colleagues have equal access to training and development opportunities;
To ensure that any promotion decisions are made on the basis of merit and performance only;
To ensure that any incidents of discrimination within their team of which they become aware are dealt with promptly and escalated as appropriate;
To liaise with any disabled team members regarding any requests for reasonable adjustments.

Colleagues' responsibilities

To treat fellow colleagues with respect and to avoid potentially offensive jokes/comments;
To report any incidents or harassment promptly in accordance with the Grievance and Whistleblowing policy.

People teams' responsibilities

To advise those with responsibility under this policy on best practice;
To advise line managers on any formal action to be taken, including drafting appropriate correspondence.