Policy statement
The Company is an equal opportunity employer and is fully committed to a policy of treating all of its employees and job applicants equally. The Company will avoid unlawful discrimination in all aspects of employment including recruitment and selection, promotion, transfer, opportunities for training, pay and benefits, other terms of employment, discipline, selection for redundancy and dismissal.

The Company will take all reasonable steps to employ, train and promote employees on the basis of their experience, abilities and qualifications without regard to age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, ethnic or national origins and caste), religion or belief, sex or sexual orientation. In this policy, these are known as the “protected characteristics”.

Employees have a duty to co-operate with the Company to make sure that this policy is effective in ensuring equal opportunities and in preventing discrimination. Action will be taken under the Company’s disciplinary procedure against any employee who is found to have committed an act of improper or unlawful discrimination. Serious breaches of this equal opportunities policy
statement will be treated as potential gross misconduct and could render the employee liable to summary dismissal. Employees should bear in mind that they can be held personally liable for any act of unlawful discrimination.

You should draw the attention of your line manager to suspected discriminatory acts or practices. You must not victimise or retaliate against an employee who has made allegations or complaints of discrimination or who has provided information about such discrimination. Such behaviour will be treated as potential gross misconduct in accordance with the Company’s disciplinary
procedure. You should support colleagues who suffer such treatment and are making a complaint. The Company has a separate dignity at work policy statement which deals with harassment, bullying and intimidation and sets out how complaints of that type will be dealt with.

Direct discrimination
Direct discrimination occurs when, because of one of the protected characteristics, a job applicant or an employee is treated less favourably than other job applicants or employees are treated or would be treated.

The treatment will still amount to direct discrimination even if it is based on the protected characteristic of a third party with whom the job applicant or employee is associated and not on the job applicant’s or employee’s own protected characteristic. In addition, it can include cases where it is perceived that a job applicant or an employee has a particular protected characteristic when in fact they do not.

Discrimination after employment is also unlawful if it arises out of and is closely connected to the employment relationship, for example refusing to give a reference or providing an unfavourable reference for a reason related to one of the protected characteristics. The Company will take all reasonable steps to eliminate direct discrimination in all aspects of employment.


Indirect discrimination 

Indirect discrimination is treatment that may be equal in the sense that it applies to all job applicants or employees but which is discriminatory in its effect on, for example, one particular sex or racial group.

Indirect discrimination occurs when there is applied to the job applicant or employee a provision, criterion or practice (PCP) which is discriminatory in relation to a protected characteristic of the job applicant’s or employee’s. A PCP is discriminatory in relation to a protected characteristic of the job applicant’s or employee’s if:

• it is applied, or would be applied, to persons with whom the job applicant or employee does not share the protected characteristic

• the PCP puts, or would put, persons with whom the job applicant or employee shares the protected characteristic at a particular disadvantage when compared with persons with whom the job applicant or employee does not share it

• it puts, or would put, the job applicant or employee at that disadvantage, and

• it cannot be shown by the Company to be a proportionate means of achieving a legitimate aim. The Company will take all reasonable steps to eliminate indirect discrimination in all aspects of employment.


Victimisation occurs when an employee is subjected to a detriment, such as being denied a training opportunity or a promotion, because they have raised or supported a grievance or complaint of unlawful discrimination, or because they have issued employment tribunal proceedings for unlawful discrimination or they have given evidence in connection with unlawful discrimination proceedings brought by another employee. However, an employee is not protected if they give false evidence or information, or make a false allegation, and they do so in bad faith.

Post-employment victimisation is also unlawful, for example refusing to give a reference or providing an unfavourable reference because the former employee has done one of the protected acts set out above.

The Company will take all reasonable steps to eliminate victimisation in all aspects of employment.

Recruitment, advertising and selection

The recruitment process will be conducted in such a way as to result in the selection of the most suitable person for the job in terms of relevant experience, abilities and qualifications. The Company is committed to applying its equal opportunities policy statement at all stages of recruitment and selection.

Advertisements will aim to positively encourage applications from all suitably qualified and experienced people. When advertising job vacancies, in order to attract applications from all sections of the community, the Company will, as far as reasonably practicable:

1. Ensure advertisements are not confined to those areas or publications which would exclude or disproportionately reduce the numbers of applicants with a particular protected characteristic.

2. Avoid setting any unnecessary provisions or criteria which would exclude a higher proportion of applicants with a particular protected characteristic.

Where vacancies may be filled by promotion or transfer, they will be published to all eligible employees in such a way that they do not restrict applications from employees with a particular protected characteristic.

However, where, having regard to the nature and context of the work, having a particular protected characteristic is an occupational requirement and that occupational requirement is a proportionate means of achieving a legitimate aim, the Company will apply that requirement to the job role and this may therefore be specified in the advertisement.

The selection process will be carried out consistently for all jobs at all levels. All applications will be processed in the same way. The staff responsible for short-listing, interviewing and selecting candidates will be clearly informed of the selection criteria and of the need for their consistent application. Person specifications and job descriptions will be limited to those requirements that are necessary for the effective performance of the job. Wherever possible, all applicants will be interviewed by at least two interviewers and all questions asked of the applicants will relate to the requirements of the job. The selection of new staff will be based on the job requirements and the individual’s suitability and ability to do, or to train for, the job in question.

With disabled job applicants, the Company will have regard to its duty to make reasonable adjustments to work provisions, criteria and practices or to physical features of work premises or to provide auxiliary aids or services in order to ensure that the disabled person is not placed at a substantial disadvantage in comparison with persons who are not disabled.

If it is necessary to assess whether personal circumstances will affect the performance of the job (for example, if the job involves unsociable hours or extensive travel), this will be discussed objectively, without detailed questions based on assumptions about any of the protected characteristics.

Access to Work

The Company encourages all disabled job applicants and employees, and those with health conditions or mental health conditions, to apply to the government’s Access to Work scheme for a grant. An Access to Work grant can pay for practical support to help you either start work or stay in work. How much you may be awarded depends on your circumstances.

To qualify for an Access to Work grant in relation to employment you must:

• have a disability, health condition or mental health condition that affects your ability to work

• be aged 16 or over

• live in England, Scotland or Wales; and

• have a paid job, a job interview or be about to start a job, work experience or an apprenticeship.

In addition, your disability or health condition must either affect your ability to do a job or mean you have to pay work-related costs, for example special computer equipment. It must also either be likely to last at least a year or have already lasted at least a year.

Where you have a mental health condition, your condition must both affect your ability to do a job and mean you need support to start a new job, reduce absence from work or stay in work.

If you are awarded a grant, the money can pay for things like special equipment, adaptations to the equipment you use, fares to work if you can’t use public transport, a support worker or job coach to help you in the workplace and a communicator at a job interview.

You can apply for an Access to Work grant either online (https://www.gov.uk/access-towork/apply) or by phoning the Access to Work scheme on 0345 268 8489. Once you have applied, an Access to Work advisor will then contact the Company and may also wish to visit you at work.

If you are eligible, the Company encourages you to apply for an Access to Work grant either before starting work for us or within six weeks of your start date as the grant may then cover all of the agreed costs, rather than just a proportion of them.

Access to Work is a government scheme and eligibility is strictly governed by the terms set by the government from time to time. It is also entirely the government’s decision as to whether to award you a grant.

The Company has no responsibility or liability for decisions made by the government.

Training and promotion

The Company will train all line managers in the Company’s policy on equal opportunities and in helping them identify and deal effectively with discriminatory acts or practices. Line managers will be responsible for ensuring they actively promote equality of opportunity within the departments for which they are responsible.

The Company will also provide training to all employees to help them understand their rights and responsibilities in relation to equal opportunities and what they can do to create a work environment that is free from discrimination.

Where a promotional system is in operation, it will not be discriminatory and it will be checked from time to time to assess how it is working in practice. When a group of workers who predominantly have a particular protected characteristic appear to be excluded from access to promotion, transfer and training and to other benefits, the promotional system will be reviewed to ensure there is no unlawful discrimination.

Terms of employment, benefits, facilities and services

All terms of employment, benefits, facilities and services will be reviewed from time to time, in order to ensure that there is no unlawful direct or indirect discrimination because of one or more of the protected characteristics.

Equal pay and equality of terms

The Company is committed to equal pay and equality of terms in employment. It believes its male and female employees should receive equal pay where they are carrying out like work, work rated as equivalent under a job evaluation study or work of equal value. In order to achieve this, the Company will endeavour to maintain a pay system that is fair and transparent, free from gender bias and based on objective criteria.

[Where it is legally obliged to do so, the Company will also prepare and publish an annual gender pay gap report in accordance with statutory requirements from time to time in force.]

Reporting complaints

All allegations of discrimination will be dealt with seriously, confidentially and speedily. The Company will not ignore or treat lightly grievances or complaints of unlawful discrimination from employees.

If you wish to make a complaint of discrimination, you should do so promptly and use the Company’s grievance procedure.

If your complaint relates to bullying, harassment or intimidation, you should refer to the Company’s dignity at work policy statement.

Monitoring equal opportunity

The Company will regularly monitor the effects of selection decisions and personnel and pay practices and procedures in order to assess whether equal opportunity is being achieved. This will also involve considering any possible indirectly discriminatory effects of its working practices. If changes are required, the Company will implement them. The Company will also make reasonable adjustments to its standard working practices to overcome substantial disadvantages caused by disability.