The Company is committed to the policy of equal treatment of all employees and applicants. The Company’s aim is to recruit, train, promote and reward on the basis of merit and irrespective of gender, disability, sexual orientation, marriage or civil partnership, gender reassignment, part-time status, age, religion or belief, race, colour, ethnic origin, nationality or national origin or Trade Union membership, political views or affiliations.

The Company is therefore committed to providing equality of opportunity for all employees by:

• Preventing any form of direct or indirect discrimination or victimisation or bullying.
• Promoting a good and harmonious working environment where all individuals are treated with respect and dignity and in which no form of intimidation or harassment from colleagues, customers or Clients will be tolerated.
• Fulfilling all legal obligations under relevant national and European Union legislation and associated Codes of Practice where they apply.

All employees must be aware of the importance which the Company attaches to its Equal Opportunities Policy, and must ensure that they do not, by their own actions, behaviour or attitudes, directly or indirectly or unintentionally discriminate against any job applicants, employees, customers or Clients. Any act of discrimination will be treated as a disciplinary offence; these will include for example, discrimination in selecting, promoting or training, refusing to work with or for a person because of any of the reasons stated in paragraph one of this policy and harassment of any employee, customer or Client.

Direct Discrimination

Unlawful direct discrimination occurs when a person is treated less favourably than another because of a protected characteristic of gender, gender reassignment, race, disability, sexual orientation, marriage or civil partnership, part-time status, age, religion or belief, colour, ethnic origin, nationality or national origin or Trade Union membership, political views or affiliations. Direct discrimination, for example, can occur where a person is refused a job, training or promotion in any of these circumstances.

Indirect Discrimination

Unlawful indirect discrimination is when a provision, criterion or practice is applied to all people but which, in practice, is such that fewer people in certain groups are able to comply and it cannot be shown to be a proportionate means of achieving a legitimate aim. Some practices may look fair but have an unintended discriminatory effect. For example if the Company made a GCSE English qualification a requirement as selection criteria, this would have a disproportionate adverse impact on people educated overseas and may not be justified if all that is required for the job is to demonstrate a level of literacy or the ability to communicate with others. The necessary level of literacy can be tested or checked in other ways that are more relevant to the job.

Time Off for Religious Observance

The Company will consider any request made for time off to observe particular religious commitments sympathetically and with sensitivity. For example, if an employee needs to be home by a certain time on Friday or Saturday to observe the requirements of their faith, the Company will review the duties of that employee to see if it is feasible to accommodate this request. Where possible, such requests will be agreed and time may be taken as unpaid time off or made up at a different time which suits the Company.

If the work simply cannot be done at another time, then the Company will be unable to agree to the request as it would mean that the business operation would suffer. The same type of consideration will be given to practising Christians who may not wish to work on Sunday or to refrain from working at Christmas or Easter.

Consideration will also be given to the locations and the timings of meetings and functions. The Company will treat employees’ beliefs and religion with sensitivity. For example, locations for business meetings will be checked regarding alcohol if one of the people required to attend the meeting follows a doctrine which prevents them from attending meetings at such a place. The timing of routine meetings will, as far as possible, not be arranged when employees who follow a particular religion would be unable to attend due to that religion.

Some religions require their followers to pray at specific times during the day. The Company will allow time off for quiet prayer which can be taken at times convenient to the business and in a convenient place. This time will be unpaid unless it can be made up at a time which is convenient to the Company.

If employees request time off for religious practices, such requests will be treated with sensitivity, and the Employee’s duties and the impact on the business considered carefully.

Any employee who wishes to make a request under this section of the policy should talk to their Line Manager who will discuss their requirements to see if these can be accommodated

Using Holidays

Sensitive consideration will be given to requests to take holiday (or unpaid leave or flexitime) to observe religious holidays. Wherever possible, the Company will agree to these requests. However, if the Company has a legitimate business reason for refusing any request then this will be the outcome as the Company is permitted to make these decisions based on the need to operate the business effectively. If requests are made with as much notice as possible being given it may be more likely that these can be accommodated and planned for in the business work schedule.

Harassment

Harassment is defined as unwanted conduct which can be physical, verbal or non verbal that either violates a person's dignity, or creates an intimidating, hostile, degrading, humiliating or offensive environment for that person. It may be related to gender, gender reassignment, race, disability, sexual orientation, marriage or civil partnership, part-time status, age, religion or belief, colour, ethnic origin, nationality or national origin or Trade Union membership or any personal characteristic of the individual. It may be persistent or an isolated incident. It can take many forms, from relatively mild banter to actual physical violence.

Employees may not always realise that their behaviour constitutes bullying or harassment but they must recognise that what is acceptable to one person may not be acceptable to another.

The Company has a separate Dignity at Work Policy.

Procedure for Dealing with a Complaint of Unlawful Discrimination

Complaints about, or reports of, discriminatory behaviour or harassment should be made through the Company Grievance Procedures.

Complaints should be raised as soon as possible so that the matter can be dealt with quickly. The matter should be raised first with the complainant’s Line Manager. If this would cause embarrassment or if the complainant feels it inappropriate, for example if the Line Manager is the subject of the complaint, then the matter should be raised with another, possibly more senior manager.

If an employee experiences any discriminatory behaviour from a third party such as customers or Clients, they should raise the matter immediately with their Line Manager or any other manager present at the place of work. The matter will be treated seriously and the manager will carry out a full investigation.

Accusation of Unlawful Discrimination

Any accusations of unlawful discrimination will be investigated fully by the Company. As part of the investigation, the Employee will be given every opportunity to answer the allegation and provide an explanation of their actions.

Once the investigation is complete, if the Company finds that no unlawful discrimination occurred, no further action will be taken. However if the Company decides that the Employee’s actions amount to unlawful discrimination, the Employee may be subject to disciplinary action up to and including summary dismissal for gross misconduct.

If, after the investigation is complete, it is found that the claim is false or malicious, disciplinary action may be taken against the Employee who raised the complaint.

Equal opportunities practice is constantly developing as social attitudes and legislation changes. The Company will keep its policies under review and will implement changes where these could improve equality of opportunity.

Victimisation

If any employee is victimised because they have supported another employee who has a protected characteristic, that employee will have the same protection as if they had that protected characteristic.

For example, one employee gives a statement confirming that they witnessed the other employee being harassed due to their race. The witness is then victimised and pressure is brought in an attempt to get them to withdraw the statement. The witness will then be protected in the same way as the original employee who was being harassed.