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Anti-Discrimination Policy

1. Statement

Our Anti-discrimination policies require employees to sign formal contracts of employment that require them to abide by company policy at all times.

These policies are set out in a comprehensive Staff Handbook.

The following sections detail our Anti-discrimination policies and reflect the latest copy of the Staff Handbook.

2. Equal Opportunities

2.1 What does this mean?

The Company is committed to providing and promoting opportunities for staff and job applicants. We are committed to creating a working environment which enables everyone to work to the best of their skills and abilities and without the threat of discrimination or harassment arising. As a Company we pride ourselves on treating all members of staff equally, irrespective of their or their “Associated Persons” gender, sex, pregnancy or maternity status, marital status, race, colour, religion or belief, disability, age, sexual orientation, gender reassignment (“Protected Characteristics”). An Associated Person may be a member of staff’s family, friends or other dependants.

Whilst the Company is committed to treating all employees equally, the success of this policy requires equal input from all employees.

All employees are required to comply with their obligations to promote a working environment free from discrimination. You should treat your colleagues, customers and members of the public as you would expect to be treated yourself and respect the Protected Characteristics of others.

2.2 Does this apply to the recruitment process?

We aim to ensure that no job applicant suffers from discrimination of any form during the recruitment process. Our application and interview process are reviewed regularly to ensure that they do not put any particular group at a disadvantage.

We will not ask unnecessary questions about an applicant’s personal affairs during the recruitment process. Questions about a prospective employee’s health will usually be left until the offer stage unless the questions are raised to identify any particular needs for the recruitment process, for a genuine occupation need or because we wish to establish at the outset the ability of a candidate to perform an intrinsic feature of the job i.e. heavy lifting.

As part of the recruitment process, we will require all prospective employees to produce appropriate ID (originals must be produced) to demonstrate that individual’s legal right to work in the UK before employment is allowed to commence.

We may, as part of any equal opportunities monitoring programme, request job applicants to complete an Equal Opportunities Form which will be detachable from the main application and used solely for the purpose of monitoring equal opportunities.

2.3 What is discrimination?

Discrimination can take a number of different forms:

Treating someone less favourably because of one or more protected Characteristic i.e. rejecting a job applicant because they are a different race or are pregnant. This is known as direct discrimination.

Applying an unjustified provision, criterion or practice which, although applied equally across all employees or job applicants, places some individuals with a particular Protected Characteristic, at a disadvantage i.e. requiring job applicants to have 10 years’ driving experience would prevent individuals under the age of 27 from applying for the role. Unless this requirement for 10 years’ driving experience can be justified this will be an act of indirect discrimination.

Bullying or harassment - see section 3 below.

Treating someone less favourably because they have raised a complaint of discrimination or given information about discrimination or supported a colleague's complaint. This is known as victimisation.

There are additional acts of discrimination which extend to staff who suffer from a disability (whether mental or physical).

The law governing equality within the workplace extends protection to members of staff who have an association with a person with a Protected Characteristic. For example, an act of discrimination may arise where a staff member is harassed or feels harassed because they have a child who is disabled.

You should also be aware that protection is extended to those who are “perceived” to have a Protected Characteristic but in fact don’t. For example, subjecting a member of staff to homophobic banter because it is perceived, albeit incorrectly, that the member of staff is not heterosexual.

Although discrimination may appear to be complicated, members of staff are unlikely to breach our policy and the law as long as they treat all colleagues with respect and dignity regardless of a person’s Protected Characteristics.

No one will be denied access to training or promotion on grounds of any Protected Characteristics.

No member of staff will have their employment or engagement terminated because of a Protected Characteristic.

Access to services, benefits and facilities will be made available to all staff equally having regard to their grade or position.

2.4 Will reasonable adjustments be made if I have a disability?

If an applicant is unable to attend an interview or other recruitment stage for any reason, we will consider any reasonable adjustments that may assist the applicant in participating fully in the recruitment process and being given an equal opportunity to be considered for any vacancy.

Similarly, as an employee of the Company, we encourage you to discuss any condition you may have with us so that we can help you overcome or minimise any difficulty you may be experiencing in the workplace (whether a physical feature or compliance with a policy or procedure) or in the performance of your duties. This will allow the Company to explore any reasonable adjustments that could be made to keep you in employment or, where absent from work, to facilitate a return to work.

2.5 Will I receive training on equal opportunities?

As part of the induction process, you will be provided with suitable training concerning equal opportunities.

We will monitor staff training needs and where a training gap is identified, all staff will be given access to suitable training to ensure they are fully aware of their obligations.

If any member of staff feels they require additional support and training in this area, they should contact their line manager accordingly.

3. Anti-bulling

3.1 How does this policy affect me?

The Company is committed to ensuring that all members of staff are treated with dignity and respect regardless of whether they have a Protected Characteristic (as explained in Section 4 above) or not. Where an employee feels that they have been subjected to harassment and bullying, they should draw such matters to the attention of their line manager.

The Company takes all allegations of bullying and harassment with the upmost seriousness and where the allegations are proven to be true, the employee at fault will be subject to our disciplinary process.

Harassment and bullying is a misconduct offence, however where it is sufficiently serious, this will be categorised as gross misconduct which may lead to your dismissal. Each case will be considered on its own facts.

3.2 What is harassment?

Harassment is any unwanted physical, verbal or non-verbal conduct which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. This can also involve matters such as offensive jokes through to conduct of a sexual nature (i.e. unwanted sexual advances) and need only be a single incident. Harassment need not be on grounds of a Protected Characteristic. As such, unwanted conduct directed at an individual because of their weight would also be caught by the policy.

It does not matter if you did not intend to cause offence, although this may be relevant as to the severity of the matter. What matters is the effect it has on the recipient of the unwanted treatment.

3.3 What is bullying?

Bullying is categorised as offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can leave an employee feeling vulnerable, upset, humiliated, undermined or threatened.

3.4 How do I raise a complaint?

Initially, it may be possible for you to raise this issue informally with the person responsible for the unwanted behaviour. Sometimes that person maybe unaware that their behaviour is causing offence to you (i.e. rude jokes) and may genuinely be upset to learn they have caused offence. Where you are able to do so, you should explain to the employee that their behaviour is not welcomed and makes you uncomfortable and could they avoid such behaviour in the future. Make a note of any conversation you have with the person involved.

If you are unable to deal with this issue informally, you can raise a formal complaint in writing with your line manager. Your complaint should set out the full details of the unwanted conduct and include dates, times, locations, and the names of any witnesses to the unacceptable behaviour.

We will treat all complaints made with the strictest confidence and will look to investigate the issue in a prompt and timely manner.

3.5 Will a formal investigation take place?

The Company takes all complaints of bullying and harassment seriously and we will look to deal with any complaints in a timely manner.

We will undertake an investigation into the allegations and all investigations will be thorough, impartial and objective. In order to discuss the outcome of your investigation, we will invite you to a meeting within 7 days of receiving your complaint. You have the right to be accompanied to this meeting by either a fellow colleague or a Trade Union Representative.

Where your complaint relates to a fellow colleague, we will consider whether suspension on full pay or alterations to the employee’s working arrangements, pending the outcome of the investigations, is necessary.

At the conclusion of our investigation, the investigating officer will submit their report to a senior manager who will consider the matter further.

A further meeting will be scheduled with you within 7 days of receipt of this report so that we can discuss the outcome of the investigation and any proposed action. Again, you have the right to be accompanied by a fellow colleague or a Trade Union Representative.

3.6 What action may be taken?

Where the senior manager considers that an offence has occurred, the manager will take prompt action to resolve the issue.

Where the harasser or bully is a fellow employee, we will look to deal with the potential misconduct or gross misconduct offence under our disciplinary procedure. However, the outcome of the disciplinary process is a matter for the Company to determine. The aggrieved cannot dictate what action is to be taken.

The Company may explore, in certain cases, the feasibility of mediation between the harasser and the aggrieved. This may be accompanied by additional training for the harasser, either internally or externally. All staff are encouraged to consider engaging in mediation where it is offered as a solution, although the Company recognises that mediation will not always be appropriate.

Where the unwanted behaviour has stemmed from a third party, we will look to clarify the behaviour expected of their representatives or in very serious cases, ban them from our premises and/or terminate the contract with them.

Please note that any employee who deliberately provides false information or acts in bad faith as part of the investigation process, will be subject to action under the disciplinary procedure.

3.7 If I am unhappy with the outcome, do I have a right to appeal?

If you are unhappy with the outcome of the investigation, you may appeal in writing to a director within 7 days. In submitting your appeal, you should state the full grounds upon which your appeal is based.

The Company will schedule an appeal meeting with you within 7 days of receiving your letter and the appeal will be dealt with by an impartial manager who has not previously been involved with the investigation.

Again, you will be entitled to be accompanied to this meeting by a fellow employee or a Trade Union Representative.

Following this meeting, the Company will confirm its decision to you in writing within 7 days of the appeal hearing after which you will have no further right of appeal.

Approval date
1st March 2023

Next review date
Currently under Board review

Approved and authorised by
Mark Dickinson
Chief Executive Officer

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