Equal Opportunities Policy

STATEMENT OF POLICY

  1. We recognise that discrimination is unacceptable and although equality of opportunity has been a long-standing feature of our employment practices and procedure, we have made the decision to adopt a formal equal opportunities policy. Breaches of the policy will lead to disciplinary proceedings and, if appropriate, disciplinary action.
  2. The aim of the policy is to ensure no job applicant, employee or worker is discriminated against either directly or indirectly on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation.
  3. We will ensure that the policy is circulated to any agencies responsible for our recruitment and a copy of the policy will be made available for all employees and made known to all applicants for employment.
  4. The policy will be communicated to all private contractors reminding them of their responsibilities towards the equality of opportunity.
  5. The policy will be implemented in accordance with the appropriate statutory requirements and full account will be taken of all available guidance and in particular any relevant Codes of Practice.
  6. We will maintain a neutral working environment in which no employee or worker feels under threat or intimidated.

RECRUITMENT AND SELECTION

  1. The recruitment and selection process is crucially important to any equal opportunities policy. We will endeavour through appropriate training to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or unconsciously, in making these decisions.
  2. Promotion and advancement will be made on merit and all decisions relating to this will be made within the overall framework and principles of this policy.
  3. Job descriptions, where used, will be revised to ensure that they are in line with our equal opportunities policy. Job requirements will be reflected accurately in any personnel specifications.
  4. We will adopt a consistent, non-discriminatory approach to the advertising of vacancies.
  5. We will not confine our recruitment to areas or media sources which provide only, or mainly, applicants of a particular group.
  6. All applicants who apply for jobs with us will receive fair treatment and will be considered solely on their ability to do the job.
  7. All employees involved in the recruitment process will periodically review their selection criteria to ensure that they are related to the job requirements and do not unlawfully discriminate.
  8. Short listing and interviewing will be carried out by more than one person where possible.
  9. Interview questions will be related to the requirements of the job and will not be of a discriminatory nature.
  10. We will not disqualify any applicant because they are unable to complete an application form unassisted unless personal completion of the form is a valid test of the standard of English required for the safe and effective performance of the job.
  11. Selection decisions will not be influenced by any perceived prejudices of other staff.

TRAINING AND PROMOTION

  1. Senior staff will receive training in the application of this policy to ensure that they are aware of its contents and provisions.
  2. All promotion will be in line with this policy.

MONITORING

  1. We will maintain and review the employment records of all employees in order to monitor the progress of this policy.
  2. Monitoring may involve:

a) the collection and classification of information regarding the race in terms of ethnic/national origin and sex of all applicants and current employees;

b) the examination by ethnic/national origin and sex of the distribution of employees and the success rate of the applicants; and

c) recording recruitment, training and promotional records of all employees, the decisions reached and the reason for those decisions.

3. 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 staff.

MAKING REASONABLE ADJUSTMENTS

Ensuring Inclusivity: Providing Reasonable Adjustments at Work for Persons with Differing Abilities

1. Purpose 

1.1 This policy aims to explain how to access support in relation to a health condition impacting a person at work, amounting to a disability under the Equality Act 2010. The purpose of this policy is to support people with a disability at work in a pro-active, collaborative, transparent, and effective way, with a ‘human-first’ approach.  

1.2 We strongly promote diversity and inclusion, and we want people to feel confident in being accepted and supported when they are at work. We are an equal opportunities employer, will consider all reasonable adjustments, and welcome input from individuals on adjustments that could support them. 

2. Disclosure 

2.1 Disclosure is the process of a person making a current or prospective employer aware of their disability. Under the Equality Act 2010, a person with a disability has a ‘physical or mental impairment that has a ‘substantial’ and ‘long-term’ negative effect on their ability to do normal daily activities’. Disclosure is a voluntary decision and will be treated sensitively and confidentially. 

2.2 To disclose a disability, please inform your line manager, head of department, Director of People & Culture or COO about your health condition that impacts you at work. This can be done via any channel or in person. People & Culture must be notified as soon as the disclosure has been received. 

2.3 Upon disclosure, the individual will be signposted to this policy, and a confidential meeting arranged between the individual and People & Culture to explore the situation, gather information, and discuss support measures as well as relevant people to involve in the process. 

2.4 Relevant colleagues will be offered training on how best to support a person with this condition as soon as possible, if available and/or relevant. They should feel confident in applying reasonable adjustments and in how to access further support (such as relevant budgets). Managers should be aware of the need to offer potential adjustments that may be necessary, and their duty to ensure adjustments are properly implemented. 

2.5 Disclosure can happen at any time, including during recruitment, before employment begins, or at any time during employment. All disclosures will be treated with respect, with the central focus being on providing the most effective support possible.  

3. Requesting Reasonable Adjustments  

3.1 A reasonable adjustment is a change made by an employer to remove or reduce a disadvantage related to an employee’s disability when doing a job, or a job applicant’s disability when applying for a job. Broadly speaking, these may be related to provision criteria or practices (e.g requirements to sit written tests or working arrangements), a physical feature (e.g seating arrangements in an office), or the provision of an auxiliary aid (e.g assistive technology). 

3.2 A person disclosing a disability may, but does not have to, ask for reasonable adjustments to support them with challenges they are experiencing at work because of their disability. The options will be explored in a collaborative way. 

3.3 To request reasonable adjustments, a person can notify their line manager, head of department, or People & Culture of the challenges they are experiencing at work in relation to their disability and the reasonable adjustments they would like to help them overcome this. This may be done at the same time as disclosure. 

3.4 As soon as reasonably possible (and within 7 working days) an initial conversation will be held between this individual and their manager and/or people & Culture to establish possible adjustments to overcome any specific work-related challenges arising from their disability. The focus of this conversation will be on providing support for the barriers a person experiences. 

A written summary will be made of this meeting and circulated within 3 working days via email; a form is available to complete. 

3.5 If solutions are agreed and straightforward to implement (e.g in terms of cost, signoff, and time), they should be recorded in a Workplace Adjustment Agreement within 7 working days, to be reviewed annually with opportunity for the individual to address any issues during regular employee check-ins. 

3.6 If the solution is not straightforward, such as requiring budget sign-off, or if solutions are unknown, People & Culture will coordinate the involvement of experts to help identify adjustments, such as making a referral to Occupational Health. 

3.7 Unnecessary delays should be avoided, and interim measures should aim to be agreed upon in writing and provided accordingly.   

4. Independent Assessments 

4.1 An independent assessment for the purposes of identifying reasonable adjustments involves a meeting between the individual and an independent expert third party to identify potential reasonable adjustments for that person at work. The overriding purpose is to ensure the person is supported at work, though a view may also be provided on whether a person’s health condition amounts to a disability as per the Equality Act 2010.  

4.2 Referrals may be to a standard ‘Occupational Health’ professional, who support individuals with working in a way that causes least harm to their health. Alternatively, or additionally, the independent assessment may be by a body with expertise in a particular condition, if necessary. The individual will be involved in discussions about decisions to refer them to any independent parties. 

4.3 A referral and assessment may involve standard questions about how a disability may affect a person’s ability to do their job. This is important to understand to be able to provide the most effective support. Following an assessment, a report containing recommendations will be provided to the individual and their employer.

4.4 After the report has been received, a follow-up discussion should be arranged with relevant employees on similar grounds to the above within 7 working days. This conversation should identify which reasonable adjustments will be made, how they will be implemented, and any dates for review. Reasonable adjustments should be recorded in a Workplace Adjustment Agreement.  

5. Making reasonable adjustments 

5.1 The adjustments to be made should be reasonable in relation to a specific set of circumstances and require the individual’s consent to be made. Factors to be considered when assessing the reasonableness of adjustments include their:

  • effectiveness in reducing any disadvantages caused by a person’s disability at work
  • practicability, including of implementation, and potential alternatives 
  • implications on health and safety, and any potential disruption 
  • financial costs, including consideration of the availability of alternative sources of funding such as Access to Work, and the size and resources of the company.  

5.2 As much information and transparency will be provided to the individual as possible about how decisions on reasonable adjustments are reached, how they may be implemented, and the timeframes for this. 

6. Workplace Adjustment Agreement

6.1 A Workplace Adjustment Agreement is a living record of reasonable adjustments agreed to support a person with a disability at work. These provide accurate records of what has been agreed and should be accessible for the employee, their line manager and head of department, and People & Culture. Agreements should be reviewed regularly and amended as appropriate. 

6.2 As far as possible, adjustments will be set out in a positive and supportive way that is specific, measurable, achievable, relevant, and time-based. They should explain how an individual can use the adjustment when needed (e.g when a person might wish to work from home or flexible hours, and the process for communicating this to others, setting out the dates for when coaching sessions would happen, or explaining what is meant by providing ‘written instructions’). 

6.2 The Workplace Adjustment Agreement Form is available separately.  

7. Access to Work 

7.1 People with disabilities are encouraged to apply for Access to Work, a Government scheme that can help fund additional support for them at work. Employees can share the contact details of their line manager and/or People & Culture representative for these purposes. 

7.2 If any assistance is required with making an Access to Work application, employees are encouraged to seek support from their line manager. This process does not replace the procedures set out in this policy.

 

Last reviewed / updated 06/01/2025