1.0 SCOPE 

This policy applies to all employees and visitors to the Company, together with those contracted to work at or for the Company.


The purpose of this policy is to provide equality and fairness for all in our employment and not to discriminate because of race, religion or beliefs, age, material or civil partnership, gender reassignment, sexual orientation, sex, disability, pregnancy or maternity. We oppose all forms of unlawful and unfair discrimination. All employees, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.

3.0 AIMS

To promote equality of opportunity, across all the activities of the Business and to promote good relations between people of a diverse background eliminating unlawful discrimination.


4.1 The act provides a new cross-cutting legislative framework to protect the rights of individuals and advance equality of opportunity for all; to update, simplify and strengthen the previous legislation; and to deliver a simple, modern and accessible framework of discrimination law which protects individuals from unfair treatment and promotes a fair and more equal society.

4.2 The basic framework of protection against direct and indirect discrimination, harassment and victimisation in services and public functions; premises; work; education; associations, and transport.

4.3 Changing the definition of gender reassignment, by removing the requirement for medical supervision.

4.4 Levelling up protection for people discriminated against because they are perceived to have, or are associated with someone who has, a protected characteristic, so providing new protection for people like carers.

4.5 Clearer protection for breastfeeding mothers.

4.6 Applying the European definition of indirect discrimination to all protected characteristics.

4.7 Extending protection from indirect discrimination to disability.

4.8 Introducing a new concept of “discrimination arising from disability”, to replace protection under previous legislation lost as a result of a legal judgment.

4.9 Applying the detriment model to victimisation protection (aligning with the approach in employment law).

4.9.1 Harmonising the thresholds for the duty to make reasonable adjustments for disabled people.

4.9.2 Extending protection from 3rd party harassment to all protected characteristics.

4.9.3 Making it more difficult for disabled people to be unfairly screened out when applying for jobs, by restricting the circumstances in which employers can ask job applicants questions about disability or health.

4.9.4 Allowing claims for direct gender pay discrimination where there is no actual comparator.

4.9.5 Making pay secrecy clauses unenforceable.

4.9.6 Extending protection in private clubs to sex, religion or belief, pregnancy and maternity, and gender reassignment.

4.9.7 Introducing new powers for employment tribunals to make recommendations which benefit the wider workforce.

4.9.8 Harmonising provisions allowing voluntary positive action.


5.1 Direct Discrimination

The definition of direct discrimination is:

“A person (A) discriminates against another (B) if, because of a protected characteristic, A treats B less favourably than A treats or would treat others.” s13 Equality Act 2010

With the exception of age discrimination, direct discrimination can never be objectively justified.

5.2 Indirect Discrimination  Under the Equality Act, the definition of indirect discrimination has been extended to cover all of the protected characteristics (apart from pregnancy and maternity which is dealt with as indirect sex discrimination).

5.3 Protected characteristics

The Equality Act identifies 9 “protected characteristics”. These are the attributes that are currently protected under existing legislation:

  • Age;
  • Disability;
  • Gender Reassignment;
  • Marriage and Civil Partnership;
  • Pregnancy and Maternity;
  • Race;
  • Religion or Belief;
  • Sex; and
  • Sexual Orientation


5.4 Definition of Disability

“A person has a disability if the person has a physical or mental impairment and the impairment has a substantial and long-term adverse effect on his/her ability to carry out normal day-to-day activities”. s6(1) Equality Act 2010.


6.1 The Human Resources Team is responsible for ensuring the strategic development, implementation and review of the Equality and Diversity Policy and progress on the implementation of corporate and area action plans.

6.2 All managers have a responsibility to:

  • Ensure the non-discriminatory treatment of all job applicants an employees and promote equality of opportunity.
  • Identify and remove discriminatory attitudes and practices within the organisation.
  • Raise the level of employee awareness of the policy’s existence.
  • Deal fairly and speedily with any discriminatory issue raised in the course of employment.
  • Support and contribute to the monitoring and review process.
  • Be aware of the diverse needs of employee and support them appropriately and fairly.

6.3 All employees have a responsibility to:

  • Support this vision and continue to ensure that the principles of equal opportunities and diversity in the workplace are upheld.
  • Treat colleagues and stakeholders with dignity and respect.
  • Have due regard to equal opportunities in the work they do and decisions they make.
  • Promote diversity in the workplace.


The Company will take seriously any instances of non-adherence to the Equality and Diversity policy by employees. Any instances of non-adherence will be investigated and where appropriate will be considered under the relevant disciplinary policy for employees.


8.1 The Company will seek to assess the impact of its policies on employees to ensure that real improvements are being made in tackling discrimination and promoting diversity.

8.2 The Company will maintain and review the employment records of all employees in order to monitor the progress of this policy.

8.3 Monitoring may involve:

  • The collection and classification of information regarding race, in terms of Marriage and Civil Partnership, ethnic/national origin, sex, sexual orientation, disability and age of all applicants and current employees;
  • The examination by Marriage and Civil Partnership, ethnic/national origin, sex , sexual orientation, disability and age of the distribution of employees and the success rate of the applicants;
  • Recording recruitment, training and promotional records of all employees, the decisions reached and the reason for those decisions

8.4 The results of any monitoring procedure will be reviewed at regular intervals to assess the effectiveness of the implementation of this policy. Consideration will be given, if necessary, to adjusting this policy to afford greater equality of opportunities to all applicants and employees.

8.5 HR will produce annual reports on our Equal Opportunities figures which illustrate the diversity of individuals who work for or benefit from our activities.