21.1 STATEMENT ON DIVERSITY
The Firm believes that we must take a leading role in promoting diversity, not only for reasons of legal compliance, and not only because the principles of fairness and a level playing field are so fundamental to sound business practice, but because in the global market place diversity is good for business. We believe that we can all benefit from the diversity and wealth of talent in our firm.
21.2 DEFINITIONS
Equality
21.2.1 Equality is the vision or aim of creating a society free from discrimination, where equality of opportunity is available to individuals and groups, enabling them to live their lives free from discrimination and oppression.
Diversity
21.2.2 Diversity is the differences in values, attitudes, cultural perspectives, beliefs, ethnic background, sexuality, age, skills, knowledge and life experiences of each individual in any group.
21.3. THE FIRM’S COMMITMENT
General commitment
21.3.1 The Firm is committed to ensuring that the differences in values, attitudes, cultural perspectives, beliefs, ethnic background, sexuality, age, skills, knowledge and life experiences of each individual in any group are valued.
21.3.2 The Firm is committed to eliminating discrimination and promoting equality and diversity in its own policies, practices and procedures and in those areas in which it has influence. This applies to the Firm’s dealings with staff and third parties.
21.3.3 The Firm is committed to ensuring that all our clients, staff, and people who apply for employment with us are protected from unlawful discrimination or oppression.
Regulation and legislation
21.3.4 In developing and implementing its Equality and Diversity policy, the Firm is committed to complying with all current and any future anti-discrimination legislation and associated codes of practice including, but not limited to:
(a) the Equality Act 2010,
and any relevant amendments or re-enactments of such legislation
i. The Commission for Racial Equality code of practice for the elimination of racial discrimination and the promotion of equality of opportunity in employment
ii. The Equal Opportunities Commission code of practice on sex discrimination; equal opportunities policies, procedures and practices in employment
iii. The Equal Opportunities Commission code of practice on Equal Pay
iv. The Disability Discrimination Act 1995 codes of practice in relation to rights of access to facilities, services and premises in employment
v. The European Community code of practice on the protection of the dignity of men and women at work.And any relevant amendments to such codes or further codes of practice
Promoting Equality and Diversity
21.3.5 We are committed to promoting equality and diversity in the Firm as well as in those areas in which we have influence. We will ensure that all our employees are informed about this policy and that you are provided with training appropriate to your needs and responsibilities.
21.3.6 Everyone who acts on behalf of the Firm, for example recruitment consultants, will be informed of this policy and we will expect them to pay due regard to it when conducting business on the Firm’s behalf.
21.3.6 In all our dealings, including those with suppliers, contractors and agencies, we will promote the principles of equality and diversity.
21.3.7 We will make every effort to reflect our commitment to equality and diversity in our marketing and communication activities.
Forms of Discrimination
21.3.8 The following are the kinds of discrimination, which are against the Firm’s policy:
(a) Direct discrimination: where a person is treated less favourably on because of race, racial group, colour, ethnic or national origins, sex, pregnancy, marital status, disability, age, sexual orientation, gender reassignment, religion or belief.
(b) Indirect discrimination: where an apparently neutral provision, criterion or practice would put a substantially higher proportion of the members of one sex, or persons having a racial or ethnic origin, or a particular religion or belief, or a particular disability or a particular sexual orientation at a particular disadvantage compared with other persons unless that provision, criterion or practice is objectively justified by a legitimate aim and the means of achieving that aim are appropriate and necessary
(c) Victimisation: where someone is treated less favourably than others because he or she has taken action against the Firm under the relevant Act.(d) Harassment: when unwanted conduct related to any of the grounds referred to above takes place with the purpose or effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating or offensive environment. Harassment may involve physical acts or verbal and non-verbal communications and gestures. This will include physical, verbal and non-verbal acts.
22.1 EMPLOYMENT AND TRAINING
22.1.1 We will treat all employees and job applicants equally and fairly and will not discriminate unjustifiably against them. This will, for example, include arrangements for recruitment and selection, terms and conditions of employment, access to training opportunities, access to promotion and transfers, grievance and disciplinary processes, demotions, selection for redundancies, dress code, references, bonus schemes, work allocation and any other employment related activities.
Recruitment and selection
22.1.2 We will ensure that:
(a) we recruit from the widest pool of qualified candidates possible;
(b) employment opportunities are open and accessible to all on the basis of their individual qualities and personal merit;
(c) where appropriate, positive action measures are taken to attract applications from all sections of society and especially from those groups which are under-represented in the workforce;
(d) selection criteria and processes do not discriminate unjustifiably on the grounds of disability, gender, marital status, race, racial group, colour, ethnic or national origin, nationality, religion or belief, sexual orientation, or age other than in those instances where the Firm is exercising permitted positive action;
(e) wherever appropriate and necessary, lawful exemptions (genuine occupational requirements) will be used to recruit suitable staff to meet the special needs of particular groups;
(f) all agencies, agents and consultants acting for the Firm are aware of its requirement not to discriminate and to act accordingly.
Provision of courses
22.1.3 The Firm will use its best endeavours to attract participants from a diverse background and will promote its courses widely so as to attract such participants.
22.1.3 Promotion within the Firm will be based solely on merit. The selection criteria and processes for recruitment and promotion will be kept under review to ensure that there is no unjustifiably discriminatory impact on any particular group.
22.1.4 We may take positive action to encourage under-represented groups to apply for promotion opportunities. However, recruitment or promotion to all jobs will be based solely on merit.
22.1.5 We will make sure that all our employees have equal access to training and other career development opportunities appropriate to their experience and abilities. However, we will take appropriate positive action measures to provide special training and support for groups which are under-represented in the workforce and encourage them to take up training and career development opportunities.
Conditions of service
22.1.6 The Firm will treat all employees equally and create a working environment which is free from discrimination and harassment and which respects, the diverse backgrounds and beliefs of employees.
22.1.7 Terms and conditions of service for employees will comply with anti-discrimination legislation. The provision of benefits such as working hours, maternity and other leave arrangements, performance appraisal systems, dress code, bonus schemes and any other conditions of employment will not discriminate against any employee on the grounds of their gender, marital status, race, racial group, colour, ethnic or national origin, nationality, religion or belief, sexual orientation or age; or unreasonably on the grounds of their disability.
22.1.8 Where appropriate and necessary, the Firm will endeavour to provide appropriate facilities and conditions of service which take into account the specific needs of employees which arise from their ethnic or cultural background, gender, responsibilities as carers, disability, religion or belief, sexual orientation or age.
Consultants and Trainers
22.1.9 Consultants will be selected on the basis of their skills, experience and ability. Arrangements and procedures for selecting Consultants and Trainers, their terms and conditions of service, access to benefits, facilities or services and termination arrangements will be reviewed and amended where necessary to prevent discrimination on any of the forbidden grounds.
Suppliers and Service Providers
22.1.10 All lists of approved suppliers and databases of contractors, agents and other third parties who, or which, are regarded as suitable to be instructed by those within the Firm have been compiled only on the basis of the ability of those persons or organisations to undertake work of a particular type and contain no discriminatory exclusion, restriction or preference.
Clients
22.1.11 The Firm will take steps to meet the different needs of particular clients arising from its obligations under the anti-discrimination legislation. In addition, where necessary and where it is permitted by the relevant anti-discrimination legislation (for example, provisions relating to positive action or exemptions) the Firm will seek to provide services which meet the specific needs and requests arising from clients’ ethnic or cultural background, gender, responsibilities as carers, disability, religion or belief, sexual orientation, age or other relevant factors.
23.1 IMPLEMENTING THE POLICY
Responsibility
23.1.1 Ultimate responsibility for implementing the policy rests with the Director of Human Resources who is responsible for the operation of the policy.
23.1.2 All employees and consultants of the Firm are expected to pay due regard to the provisions of this Equality and Diversity policy and are responsible for ensuring compliance with it when undertaking their jobs or representing the Firm.
23.1.3 Acts of discrimination or harassment on any of the forbidden grounds by employees of the Firm will result in disciplinary action. Failure to comply with this policy will be dealt with under the firm’s disciplinary procedure. The policy applies to all who are employed in the Firm.
23.1.5 Acts of discrimination or harassment on any of the forbidden grounds by those acting on behalf of the Firm will lead to appropriate action including termination of services where appropriate.
Complaints of discrimination
23.1.6 The Firm will treat seriously, and will take action where appropriate concerning, all complaints of discrimination or harassment on any of the forbidden grounds made by employees, consultants, clients, or other third parties.
23.1.7 All complaints will be investigated in accordance with the Firm’s grievance or complaints procedure and the complainant will be informed of the outcome.
Monitoring and review
23.1.8 We will monitor and review this policy on a regular basis (and in any event at least annually) to measure its progress and judge its effectiveness. In particular, the Firm will, as appropriate, monitor and record:
(a) The gender, ethnic composition and age of the workforce as well as the number of disabled staff, at different levels of the organisation
(b) The ethnicity, gender, age and disability of all applicants, short-listed applicants and successful applicants for jobs and training contracts
(c) The ethnicity, gender, age and disability of all applicants for promotion and training opportunities and details of whether they were successful.
(d) Where it is possible to do so, and where doing so will not cause offence or discomfort to those whom it is intended to protect, the sexual orientation and religion or belief of all consultants and staff will be monitored so as to ensure that they are not being discriminated against in terms of the opportunities or benefits available to them. We are however aware that staff and participants may choose not to disclose their sexual orientation or religion or belief and care will be taken to avoid inadvertent discrimination in such cases.
(e) The number and outcome of complaints of discrimination made by staff, clients, participants and other third parties
(f) the disciplinary action (if any) taken against employees by race, gender and disability.
23.1.9 This information will be used to review the progress and impact of our Equality and Diversity policy. Any changes required will be made and implemented.