EDI Policy

Equality, Diversity & Inclusion Policy

Scope

What we expect

We expect everyone who works with us:

• 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. Individuals can be personally liable for discrimination and harassment. Definitions of discrimination, harassment, victimisation and bullying are found in the appendix to this Policy.
• To treat colleagues and third parties (including 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.
• To contribute towards creating an environment where feel able to speak up about their experiences. However, this is only possible if we treat people with dignity, trust and respect and we expect everyone to uphold these values.

How we do this

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 have attended appropriate diversity and inclusion training and must 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. The recruitment team will, in advance of a recruitment campaign, consider how 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. Job applicants will not be asked about their health or disability unless there are specific legal grounds for doing so and where appropriate consideration has been given in advance.

Career development

Any decision made relating to a person’s promotion or career development must be free from discrimination. We apply objective selection criteria and processes for recruitment and promotion and review them on a regular basis to avoid discriminatory impact.

Reasonable adjustments

We encourage those who work with us to speak to a member of our management team about any disabilities which require our support so we can explore and make reasonable adjustments to our premises or to aspects of your role, or to our working practices. There may be occasions on which we need the support or a medical practitioner and should we need to discuss your needs with any third party, we will discuss the process and your rights at that time.

Training

Any new employee joining our business will be invited to attend equality, diversity and inclusion training within their first year of employment. Further training will be offered to anyone with responsibility for making decisions about a person’s employment. This training will be repeated annually.

Monitoring and review

We request, process and report 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. Requests for information of this nature will always be accompanied by the background and reason for the request and details of the individuals’ rights in relation to it.

Appendix – Definitions of Discrimination, Harassment, Victimisation and Bullying

Discrimination is not always obvious and can be subtle and unconscious. This stems from a person’s general assumptions about the abilities, interests and characteristics of a particular group that influences how they treat those people (known as “unconscious bias”). Such assumptions or prejudices may cause them to apply requirements or conditions that put those in particular groups at a disadvantage. Different types of discrimination under the Equality Act 2010:

• 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 “wouldn’t 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 introducing a requirement for all staff to finish work at 6pm. It is arguable that female employees, who statistically bear the larger share of childcare responsibilities could be at a disadvantage if the new working hours prevent them from collecting their children from school or nursery.
• 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: Treating someone unfavourably because of something connected with that person’s disability and where such treatment is not justified.
• Failing to make reasonable adjustments: Employers are legally obliged to make reasonable adjustments to ensure that aspects of employment, or the employer’s premises, do not put a disabled person at a substantial disadvantage. Failing to comply with this duty is unlawful.

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 conduct.

Victimisation is treating another person detrimentally either because that person has made a complaint of discrimination or harassment, or because they have supported someone else who has made such a complaint, for example by giving a witness statement that supports the allegations.

Bullying does not have a legal definition. 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 work. If the bullying relates to a person’s protected characteristic, it may also constitute harassment and, therefore, will be unlawful.

Latest version updated and adopted as of 23 January 2023.