Schedule 5: Diversity, Equity and Inclusion Policy
Equal Opportunities Statement
We are an equal opportunities employer and do not discriminate on the grounds of sex, sexual orientation, marital or civil partner status, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability, age or pregnancy or maternity ("Protected Characteristics").
We are committed to promoting equal opportunities in employment. You and any job applicants will receive equal treatment regardless of Protected Characteristic. This policy does not form part of any employee's contract of employment and we may amend it at any time.
About This Policy
This policy sets out our approach to diversity, equity and inclusion. It applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.
Discrimination
You must not unlawfully discriminate against or harass other people including current and former employees, 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:
- 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.
- 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 adversely affects women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified.
- 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.
- Victimisation: retaliation against someone who has complained or has supported someone else's complaint about discrimination or harassment.
- 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. Shortlisting should be done by more than one person if possible.
Vacancies should generally be advertised to a diverse section of the labour market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying.
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 a job offer is made, except in the very limited circumstances allowed by law: for example, to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability. Where necessary, job offers can be made conditional on a satisfactory medical check. Health or disability questions may be included in equal opportunities monitoring forms, which must not be used for selection or decision-making purposes.
We are required by law to ensure that all employees are entitled to work in the UK. All prospective employees, regardless of nationality, must produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation.
Disabilities
If you are disabled or become disabled, we encourage you to tell us about your condition so that we can consider what reasonable adjustments or support may be appropriate.
Part-Time and Fixed-Term Work
Part-time and fixed-term employees should be treated the same as comparable full-time or permanent employees 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 and Capability Procedure. Serious cases of discrimination may amount to gross misconduct resulting in dismissal.
If you believe that you have suffered discrimination you can raise the matter through our Grievance Procedure or Anti-harassment and Bullying Policy. Complaints will be treated in confidence and investigated as appropriate. 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.
You must not be victimised or retaliated against for complaining about 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 under this policy or our Grievance Procedure.
Making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our Disciplinary and Capability Procedure.
Schedule 6: Anti-Harassment and Bullying Policy
About This Policy
We are committed to providing a working environment free from harassment and bullying and ensuring all staff are treated, and treat others, with dignity and respect. This policy covers harassment or bullying which occurs at work and out of the workplace, such as on business trips or at work-related events or social functions. It covers bullying and harassment by staff (which may include consultants, contractors and agency workers) and also by third parties such as customers, suppliers or visitors to our premises.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
What is Harassment?
Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment. It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.
Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may be related to sex, sexual orientation, marital or civil partner status, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability, age or pregnancy or maternity ("Protected Characteristics"). Harassment is unacceptable even if it is not related to a Protected Characteristic.
Harassment may include, for example:
- Unwanted physical conduct or "horseplay", including touching, pinching, pushing and grabbing
- Unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless)
- Offensive e-mails, text messages or social media content
- Mocking, mimicking or belittling a person's disability
A person may be harassed even if they were not the intended "target" or directly involved in a discussion or event. For example, a person may be harassed by racist jokes about a different ethnic group if the jokes create an offensive environment.
What is Bullying?
Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation.
Bullying can take the form of physical, verbal and non-verbal conduct. Bullying may include, by way of example:
- Physical or psychological threats
- Overbearing and intimidating levels of supervision
- Inappropriate derogatory remarks about someone's performance
Legitimate, reasonable and constructive criticism of a worker's performance or behaviour, or reasonable instructions given to workers in the course of their employment, will not amount to bullying on their own.
If You Are Being Harassed or Bullied
The Company encourages 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.
If you believe that you have suffered any harassment or bullying or you witness any harassment or bullying in the workplace you should raise the problem informally with the person responsible. You should explain clearly to them that their behaviour is not welcome or makes you uncomfortable. If this is too difficult or embarrassing, you should speak to HR, who can provide confidential advice and assistance in resolving the issue formally or informally.
If informal steps are not appropriate, or have not been successful, you should raise the matter formally under our Grievance Procedure. We will investigate complaints in a timely and confidential manner. The investigation will be conducted by someone with appropriate experience and no prior involvement in the complaint, where possible. Details of the investigation, the name of the person making the complaint and the person accused must only be disclosed on a "need to know" basis.
We will consider, as part of the investigation, whether any steps are necessary to manage any ongoing relationship between you and the person accused during the investigation. Once the investigation is complete, we will inform you of our decision.
If we consider you have been harassed or bullied by an employee the matter will be dealt with under the Disciplinary and Capability Procedure as a case of possible misconduct or gross misconduct. If the harasser or bully is a third party such as a customer or other visitor, we will consider what action would be appropriate to deal with the problem.
Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.
Protection and Support for Those Involved
Staff who make complaints or who participate in good faith in any investigation must not suffer any form of retaliation or victimisation as a result. Anyone found to have retaliated against or victimised someone in this way will be subject to disciplinary action under our Disciplinary and Capability Procedure.
Record-Keeping
Information about a complaint by or about an employee may be placed on the employee's personnel file, along with a record of the outcome and of any notes or other documents compiled during the process. These will be processed in accordance with our Data Protection Policy.
Schedule 7: Anti-Corruption and Bribery Policy
About This Policy
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
Who Must Comply With This Policy?
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
What is Bribery?
"Bribe" means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
"Bribery" includes offering, promising, giving, accepting or seeking a bribe. All forms of bribery are strictly prohibited.
If you are unsure about whether a particular act constitutes bribery, raise it with management. Specifically, you must not:
- Give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received
- Accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else
- Give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure
You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
Gifts and Hospitality
This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
Gifts must be:
- Of an appropriate type and value depending on the circumstances and taking account of the reason for the gift
- Not cash or cash equivalent (such as vouchers)
- Not given in secret
- Given in our name, not your personal name
Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.
Record-Keeping
You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
How to Raise a Concern
If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify management or report it in accordance with our Whistleblowing Policy as soon as possible.
Schedule 8: Whistleblowing Policy
About This Policy
We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.
This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers. This policy does not form part of any employee's contract of employment and we may amend it at any time.
What is Whistleblowing?
Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, facilitation of tax evasion, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.
How to Raise a Concern
We hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact HR. We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.
Confidentiality
We hope that you will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.
External Disclosures
The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.
The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Protect (formerly Public Concern at Work) operates a confidential helpline.
Protection and Support for Whistleblowers
We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken. Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform HR immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure.
You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action. In some cases the whistleblower could have a right to sue you personally for compensation in an employment tribunal.
However, if we conclude that a whistleblower has made false allegations maliciously or with a view to personal gain, the whistleblower may be subject to disciplinary action.
