1 Introduction
1.1 This documents sets out our policy in relation to all aspects of equal opportunities. It includes matters of discrimination, harassment, bullying and disability. Separate sections on harassment and disability are set out in Sections 6 and 7. it covers equality in terms of sex, race, disability, sexual orientation, religion and age.
1.2 Equal opportunities is a developing area and additional policies and procedures may be implemented from time to time. You will be advised if new procedures are introduced.
1.3 If you have any issues relating to equal opportunities – whether they are referred to in this document or not – please do not hesitate to contact any senior manager who will be pleased to help in any way they can.
1.4 This policy is for guidance only and does not form part of your contract of employment.
2 Policy
2.1 It is the policy of The Company to treat all applicants and employees in the same way, regardless of their gender, marital status, race, ethnic origin, hours of work, or disability in accordance with appropriate legislation.
2.2 Equality of opportunity will be achieved through the provision and adoption of policies, procedures and training which reflect and support equal opportunities throughout the Company.
2.3 All employees will be made aware of the provisions of this policy and all employees are required to ensure that the policy is carried out properly.
2.4 This policy applies to the advertisement of jobs, recruitment and appointment, training, conditions of service, pay, promotion, redundancy selection, hours of work and to every other aspect of employment.
2.5 This policy applies equally to the treatment of staff and any other person or organisation having contact with the Company.
2.6 Job applicants may be asked to complete a form denoting their sex, race, ethnic origin and any disabilities. The Company confirms that the sole purpose of this form is to monitor the effectiveness of our equal opportunities responsibilities.
2.7 Employees may be asked to complete a similar form from time to time in order that The Company is better able to monitor the makeup of its workforce. All information collected will be kept as anonymous statistical data and will not identify individual members of staff.
3. Employee Responsibility
3.1 Employees have responsibilities in the area of equal opportunity and are required to adopt the following:
- Co-operate with any measures introduced to develop or monitor equal opportunity
- Refrain from taking discriminatory actions or decisions which are contrary to the spirit of this policy
- Not to harass, abuse or intimidate other employees on account of their race, sex, disability, religion, age, etc
- Not to place pressure on other employees to act in a discriminatory manner
- Resist pressure to discriminate which is placed upon you by other employees
- Co-operate with investigations into acts or conduct which may amount to unfair or unlawful discrimination including the provision of evidence from which discrimination may be inferred and disciplinary action taken
3.2 Employees should note that the imposition of a condition or requirement which has an adverse impact on somebody because of their sex, race, ethnic origin, marital status, age or disability, or is more likely to be affected by it, will also be unlawful, unless it can be justified on grounds of business needs.
4 Enforcement and Redress
4.1 If you unfairly or unlawfully discriminate against another employee, induce others to practice unfair or unlawful discrimination, or fail to co-operate with measures designed to promote equal opportunity, you may be subject to disciplinary action.
4.2 You may use the grievance procedure to complain about discriminatory conduct. If the matter relates to harassment you should follow the harassment procedure outlined below in section 6.
4.3 The Company is concerned to ensure that staff feel able to raise such grievances and no individual will be penalised unless the grievance is found to be malicious or made in bad faith.
4.4 An employee who harasses any other employee for whatever reason will be subject to the Company’s disciplinary procedure. In serious cases, such behaviour will be deemed to constitute gross misconduct and, as such, may result in dismissal.
5 Monitoring the Policy
5.1 The Company will monitor its level of compliance with the policy on a regular basis. Details of the monitoring information is available on request.
6 Harassment
6.1 We are committed to providing a work environment for our employees which is free from embarrassment, intimidation, threats, discrimination or harassment. Harassment for whatever reason will not be tolerated under any circumstances. We will do all that is reasonably possible to prevent harassment occurring and will take all necessary steps to ensure this policy is implemented effectively.
6.2 We recognise that each employee will have a different perception of what constitutes harassment. It is not for the Company to challenge such perceptions but to treat all such matters seriously.
6.3 It is the duty of all employees, and in particular managers and supervisors, to ensure that our policy on such harassment is carried out as quickly and thoroughly as possible.
6.4 We recognise that harassment can have the effect of humiliating, offending and demeaning the employee against whom it is aimed. As a result, the effectiveness and efficiency of the company may be damaged. We consider harassment to have the potential to amount to gross misconduct, which will be dealt with under the disciplinary policy and may lead to dismissal for a first offence.
6.5 Any complaints of harassment should be made in writing to your senior manager. If this is not appropriate you should take the matter directly to another senior manager you feel is appropriate. The matter will be dealt with in a discreet and confidential manner and appropriate action taken.
6.6 Racial Harassment
Racial harassment can take on many forms. It is generally considered to be behaviour which is offensive, embarrassing, insulting or intimidating to the victim. It may include any unwanted non-verbal, verbal or physical abuse that is racially derogatory and potentially offensive.
6.7 Examples of racial harassment include offensive and insensitive quips and jokes which are related to a person’s race, religion or ethnic origin; the deliberate exclusion and isolation of an individual; threatening or insulting words or behaviour; the display of abusive writing or pictures.
6.8 Sexual Harassment
Sexual harassment consists of unwanted conduct of a sexual nature. It will include verbal, non-verbal or physical conduct of a sexual nature which the harasser knew or should have known would cause offence to the other person. Such conduct may include (although this is by no means an exhaustive list), unwanted physical conduct of a sexual nature; inappropriate, suggestive or uninvited comments; displays of sexual or sexually aggressive literature and pictures; unwelcome sexual propositions; staring and leering; or repeated unwelcome invitations; lewd comments or insensitive jokes.
6.9 Sexual harassment can apply in situations where the harasser and the other person are of the same gender.
Action You Can Take If You Believe You Are Being Harassed
6.10 The first step is to make it clear to the person who is harassing you that such behaviour is unacceptable and that you want it to stop. Person-to-person reproof at an early stage will often be sufficient to stop the harassment without involving third parties. Alternatively, you could seek the help of a trusted colleague and ask them to approach on your behalf the person causing offence.
6.11 If the behaviour continues you should consult your manager, who will be able to advise you on what to do next – this may be to make a formal complaint.
6.12 If your manager or supervisor is harassing you, you should seek advice from his or her manager.
6.13 It is important to keep a written record of such incidents so that you can accurately report what has happened, noting for example the date, time and nature of incidents and the names of any witnesses. If any of your colleagues are being harassed by the same person ask them to keep records too.
6.14 Once you register a complaint it will be fully investigated and where appropriate disciplinary action will be taken. You will not be penalised for bringing a claim which later turns out to be unsubstantiated unless your actions were obviously a case of victimisation of another employee .
7 Disability Policy
7.1 It is the policy of The Company to give reasonable consideration to providing facilities for recruitment, employment and promotion of disabled employees.
7.2 We are also committed to the aim of continuing to employ those who may become disabled during the course of their employment but remain capable of working.
7.3 The Company is also committed to preventing and discouraging harassment or victimisation of any employee because of his or her disability. We recognise that disabled employees may be the recipients of unwanted conduct based on their disability. Offensive or intimidating behaviour towards a person because of his or her disability (including any impediment of movement, touch, vision or hearing) should immediately be disclosed to your manager. We will offer support to any employee subjected to such harassment and will take disciplinary action against offenders.
Recruitment
7.4 We recognise the specific and particular difficulties that may arise where applicants for positions with us have disabilities. In order to minimise possible discrimination, and to ensure that those with disabilities have every opportunity to be considered for jobs the following procedures will be followed:
- All applicants will be asked to complete an equal opportunities monitoring form. This will allow identification of any disability
- When shortlisted for interview all applicants will be asked if there are any specific matters which we may need to be aware of; eg, access requirements, seating arrangements, dietary needs, accompaniment, etc
- For successful candidates the completion of a medical questionnaire so that we may be aware of all disabilities in order to make necessary changes to workplace, etc
Employee Responsibility
7.5 You have a duty to co-operate with us to ensure that this policy is effective, and to ensure that colleagues are treated with respect and dignity. You should support colleagues who suffer disability harassment and are making a complaint. You should make it clear that you find such behaviour unacceptable and report any such behaviour you may observe.
7.6 You are reminded that disability harassment is regarded as gross misconduct. All such allegations will be dealt with quickly and discreetly. Complaints of disability harassment should be made in accordance with The Company procedure on bullying.



