Diversity, Equity and Inclusion

Our Commitments

We are committed to promoting equal opportunities in employment and creating a workplace culture in which diversity and inclusion is valued and everyone is treated with dignity and respect. As part of our zero-tolerance approach to discrimination in any form, you and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics). We are also committed to providing equitable treatment to all those we deal with as an organisation, including customers and suppliers.

We will take all reasonable steps to:

1. Promote awareness and provide training to all staff and all managers on all aspects of equality and diversity in the workplace.
2. Apply the principles of equity to all staff and all job applicants so that there is equality of opportunity. Our aim is that no individual is denied employment opportunities for reasons unrelated to ability.
3. Establish programmes and processes that ensure a diversity of candidates at all career stages, beginning with recruitment, including the development and promotion of talent through to the appointment of senior leadership.
4. Implement all internal policies and procedures (on a fair and impartial basis).
5. Create an inclusive working environment that is sensitive to the needs of staff of differing cultures, religions and beliefs. For example, in connection with festivals, religious observance and dress.
6. Set measurable equality, diversity and inclusion targets for the organisation [and report the progress made in achieving those targets to employees regularly.
7. Make reasonable adjustments to enable employees with disabilities to function effectively and to their full potential.
8. Ensure that all work environments are free from all forms of discrimination, harassment, intimidation or bullying.
9. Monitor how this policy is working in practice.

About this policy

The purpose of this policy is to set out our approach to diversity, equity and inclusion. Our aim is to encourage and support diversity, equity and inclusion and actively promote a culture that values difference and eliminates discrimination in our workplace. It applies to all aspects of employment with us, including recruitment, pay, benefits and conditions, flexible working and leave, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.

This policy has been implemented by senior Management.

This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.

Who does this policy apply to?

This policy applies to all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers.

Who is responsible for this policy?

Our Director is responsible for the effective operation of this policy but has delegated day-to-day responsibility for overseeing its implementation to the HR Department. Questions about the policy or suggestions for change should be referred to the HR Department.

We also have workplace equality champions within the organisation who are trained to support individuals who have suffered discrimination, harassment or victimisation through the process of raising a complaint. Their role is to advocate for and monitor diversity, equity and inclusion issues and oversee training.

All managers must set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives with regard to diversity, equity and inclusion.

This policy is reviewed annually by the Director.

Diversity and inclusion training

Managers will be given appropriate training on recognising and avoiding discrimination, harassment, victimisation[, unconscious bias] and promoting equality of opportunity and diversity in the areas of recruitment, development and promotion. The HR Department has overall responsibility for equality training for staff and managers, as appropriate.

We will provide you with regular training to ensure that everyone is aware of and understands the contents of this policy [and the Anti-harassment and Bullying Policy]. Following the training, you will be required to confirm that you have read, understand and will comply with this policy and the Anti-harassment and Bullying Policy. We will also provide [equality and diversity training regularly].

Discrimination

You must not unlawfully discriminate against or harass other people, including current and former staff, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts or when wearing a work uniform), and on work-related trips or events, including social events.

The following forms of discrimination are prohibited under this policy and are unlawful:

a) Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay. Direct discrimination can include associative discrimination, where a person is treated less favourably because of their association with an individual with a Protected Characteristic, and perception discrimination, where a person is treated less favourably because of the mistaken belief that they possess a Protected Characteristic.

b) Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others, and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified.

c) Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. [Harassment is dealt with further in our Anti-harassment and Bullying Policy.]

d) Victimisation: retaliation against someone who has complained or has supported someone else's complaint about discrimination or harassment. This includes where someone mistakenly believes that the person victimised has done so.

e) Disability discrimination: this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.

Recruitment and selection

Recruitment, promotion, and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. When recruiting or promoting, we will aim to take steps to improve the diversity of our workforce and provide equality of opportunity. Shortlisting [and interviewing] should be done by more than one person and with the involvement of the HR Department, where possible. Our recruitment procedures will be reviewed regularly to ensure that individuals are objectively assessed on the basis of their relevant merits and abilities.

Vacancies should generally be advertised to a diverse section of the labour market by [using a variety of social media channels as well as] using recruitment agencies which provide a diverse range of suitable candidates. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. [They should include a short policy statement on equal opportunities and the employer's commitment to diversity, equity and inclusion in the workplace and state that a copy of this policy will be made available on request.]

We will take steps to ensure that our vacancies are advertised to a diverse labour market and, where relevant, to particular groups that have been identified as disadvantaged or underrepresented in our organisation, and reach the widest possible candidate pool. In order to address underrepresentation of certain groups within our organisation, these steps may include actively inviting applications from underrepresented groups, offering internships or mentorships to certain groups or other such lawful steps. [Where appropriate, the HR Department may approve the use of lawful exemptions to recruit someone with a particular Protected Characteristic, for example, where the job can only be done by a woman. The advertisement should specify the exemption that applies.

Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children.

Job applicants should not be asked about health or disability before making a job offer. There are limited exceptions which should only be used with the approval of the HR Department. For example:

a) Questions are necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).

b) Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at the interview or assessment.

c) Positive action to recruit disabled persons.

d) Equal opportunities monitoring (which will not form part of the selection or decision-making process).

Job offers can be made where necessary based on a satisfactory medical check.

We are 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 the HR Department or UK Visas and Immigration.

To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in our organisation, we monitor applicants' ethnic group, nationality, gender, gender identity, disability, sexual orientation, religion and age as part of the recruitment procedure. Provision of this information is voluntary and it will not adversely affect an individual's chances of recruitment or any other decision related to their employment. The information is removed from applications before shortlisting, and kept in an anonymised format solely for the purposes stated in this policy and in accordance with data protection legislation. [We may also continue to monitor the employment experience of those with certain protected characteristics to identify any inequalities and areas in which further support or changes are required to achieve equality of experience.] Analysing this data helps us take appropriate steps to avoid discrimination and improve equality, diversity and inclusion.

Training, promotion and conditions of service

Training needs will be identified through regular appraisals which will be based entirely on an objective assessment of performance and will not be influenced by any Protected Characteristics that you may have. You will be given appropriate access to training to enable you to progress within the organisation and all promotion decisions will be made on the basis of merit.

Workforce composition, training and promotions 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 unjustified barriers and to meet the specific needs of disadvantaged or underrepresented groups.

Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all of you who should have access to them and that there are no unlawful obstacles to accessing them.

Employee groups and networks

We support the formation of employee affinity groups and networks as a key part of our diversity and inclusion strategy. These groups and networks bring together workers from across the business with the objective of promoting the cause of those who are historically underrepresented including women, ethnic minorities, LGBTQ+ individuals, and those with disabilities and their carers. They are organised as employee-driven associations that are open to all, where workers can participate locally and virtually on a voluntary basis.

Monitoring

We will monitor the effectiveness of our policies and procedures in meeting our diversity, equity and inclusion objectives and to identify areas in which further resources or support are required to achieve equality of experience.

We will also monitor the treatment and outcomes of any complaints of discrimination, harassment or victimisation we receive to ensure that they are properly investigated and resolved, those who report or act as witnesses are not victimised, repeat offenders are dealt with appropriately, cultural clashes are identified and resolved and workforce training is targeted where needed.

We will regularly share with you the progress and achievements we have made towards our diversity, equity and inclusion objectives.

Termination of employment

We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.

We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.

Disabilities

If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate.

If you experience difficulties at work because of your disability, you may wish to contact your line manager to discuss any reasonable adjustments that would help overcome minimise the difficulty. Your line manager may wish to consult with you and your medical adviser about possible adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable, we will explain our reasons and try to find an alternative solution where possible.

We will monitor the physical features of our premises to consider whether they might place anyone with a disability at a substantial disadvantage. Where necessary, we will take reasonable steps to improve access.

Part-time and fixed-term work

Part-time and fixed-term staff should be treated the same as comparable full-time or permanent staff and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.

Breaches of this policy

We take a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure. Serious cases of deliberate discrimination and victimisation may amount to gross misconduct resulting in dismissal.

If you believe that you have suffered harassment, bullying or discrimination, or witnessed it happening to someone else in the workplace, you can raise the matter [using the procedure set out in this policy] [through our Grievance Procedure] [and through our Anti-harassment and Bullying Policy as appropriate]. Complaints will be treated in confidence and investigated as appropriate.

There must be no victimisation or retaliation against staff who complain about or report discrimination. If you believe you have been victimised for making a complaint or report of discrimination, or have witnessed it happening to someone else in the workplace, you should raise this through the procedure set out in this.

We encourage the reporting of all types of potential discrimination, as this assists us in ensuring that diversity, equity and inclusion principles are adhered to in the workplace. However, making a false allegation in bad faith, or that you know to be untrue, will be treated as misconduct and dealt with under our Disciplinary Procedure.