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Equality, Diversity and Inclusion Policy

ABOUT THIS POLICY

1.1       This is the Equality, Diversity and Inclusion Policy for Go To Places Ltd and Visit Kent Ltd (the ‘Group’). The Group is committed to embedding equality, diversity and inclusion within the organisation, and to eliminating unlawful discrimination.   The policy defines and Group’s approach and it sets out how we will ensure fairness as an employer.  The aim is for the workforce to be truly representative of all sections of society, and for each employee to feel respected and able to give their best.

 

1.2       This policy applies to all employees, agency workers and self-employed contractors, in addition to volunteers, students on work placement from schools or colleges, and visitors to Group premises.  It applies in the workplace, and on work related trips or events including social events.  It is a condition of employment that all staff act in accordance with this policy.  Failure to do so will result in the disciplinary procedure being instigated.

 

1.3       The Protected Characteristics defined in the Equality Act 2010 are: Age, Disability, Gender Reassignment, Marriage and Civil Partnership, Pregnancy and Maternity, Race,            Religion or Belief, Sex, Sexual Orientation. The Equality Act bans discrimination against any individual because of one or more of these characteristics.  Discrimination can include direct discrimination, indirect discrimination, discrimination by perception or association, harassment, victimisation, disability related less favourable treatment, failure to comply with the duty to make reasonable adjustments, and social exclusion.

1.4       The Group has a legal responsibility to ensure that unlawful discrimination does not occur within the business.

1.5       In addition to the Protected Characteristics defined above, the Group’s Policy includes characteristics pertaining to socio-economic status,  life experience and personality.

1.6       This policy does not form part of any employee’s contract of employment and may be      amended at any time.

 

  1. DEFINITIONS

 

Term

Definition

Equity

Equality means each individual or group of people is given the same resources or opportunities. Equity recognizes that each person has different circumstances and allocates the exact resources and opportunities needed to reach an equal outcome.  The organisation recognises that:

• Everyone has individual needs and the right to have those needs respected

• Inequalities exist between people and that unlawful discrimination needs to be tackled

 • Employment practices and commissioned services should be accessible to all.

Diversity

Diversity is based on a principle of recognising, responding to, and valuing visible and non-visible differences amongst individuals and groups so that everyone can thrive and contribute. Diversity can include people with varying backgrounds, experiences, styles, perceptions, values and beliefs.

Inclusion

The practice or policy of providing equal access to opportunities and resources for people who might otherwise be excluded or marginalised.

Protected characteristics

The protected characteristics defined in the Equality Act 2010 are:

• Age – Refers to a person with a particular age or being within an age band or group

• Disability - A person who ‘has a physical or mental impairment which has a substantial and long-term adverse effect on his/ her ability to carry out normal day to day activities’. Long term is defined as at least 12 months. Progressive illnesses are also covered

• Gender Reassignment. The Equality Act prohibits discrimination against a person who is proposing to undergo, is undergoing or has undergone a process, or part of a process, for the purpose of reassigning their sex

• Marriage and civil partnership - between a man and a woman, or between members of the same sex.

 • Pregnancy and maternity - The condition of being pregnant or the period after giving birth

 • Race - Group of people defined by their colour, nationality, ethnic or national origins • Religion or belief - The religion a person belongs to. A belief, including lack of belief, should affect your life choices or the way you live for it to be included

• Sex – Gender, someone being a man or a woman

• Sexual orientation - Whether a person’s sexual attraction is towards their own sex, the opposite sex, to both sexes or to neither sex.

Prohibited conduct

The Equality Act bans direct discrimination, indirect discrimination, discrimination by perception or association, harassment, victimisation, disability related less favourable treatment, failure to comply with the duty to make reasonable adjustments, and social exclusion

Direct discrimination

Means treating someone less favourably compared to others because:

 • They have certain protected characteristics

• They are thought to have a protected characteristic (discrimination by perception).

 • Because they are associated with someone who has a protected characteristic (discrimination by association).

• Failure to make reasonable adjustments for disabled persons.

Indirect discrimination

Can occur when an apparently neutral provision or policy that applies to everyone disadvantages a person with a particular protected characteristic (this can be unintentional)

Harassment

A form of discrimination defined in the Equality Act 2010 as ‘unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual’. The conduct need not be repeated, so a serious one-off incident could still be regarded as harassment. It does not matter whether or not a harasser intended their behaviour to be offensive. The perception of the person experiencing harassment must be taken into particular account when deciding if harassment has taken place.

Victimisation

This takes place when a person is treated less favourably than others in the same circumstances because it is suspected or known that he/ she has brought proceedings under the Act or has given evidence or information relating to such proceedings or alleged that discrimination has occurred.

Positive action

The Act permits employers to take positive action to overcome the effects of disadvantage experienced by a protected group (for example by meeting the specific needs of the group or by enabling or encouraging members of the group to participate in an activity where they are currently under-represented). 

Reasonable adjustment

 

Organisations making adjustments to the way in which they carry out their functions so that disabled people are not disadvantaged by the way in which those functions are carried out. For example, arranging and paying for sign language interpreters to enable a deaf person to participate in a meeting.

Bullying

Bullying in the workplace is defined as persistent, intimidating, humiliating behaviour, which attempts to undermine an individual or group of employees. Examples of bullying include:

 • Ignoring views and opinions

• Withholding information that can affect a worker’s performance

• Setting unreasonable or impossible deadlines

 • Setting unmanageable workloads

 • Humiliating staff in front of others

 • Spreading malicious rumours

 • Intentionally blocking promotion or training opportunities

 • Ridiculing or demeaning someone by picking on them or setting them up to fail

• Overbearing supervision or other misuse of power or position

• Deliberately undermining a competent worker with constant criticism

• Cyber-bullying using email, text messages, social media, camera phones.

Human Rights

The Human Rights Act 1998 sets out 15 fundamental rights and freedoms that individuals in the UK have access to. The Group must act compatibly with and safeguard these rights. In practice this means treating individuals with fairness, respect, equality, dignity and autonomy whilst also safeguarding the rights of the wider community when developing policies and procedures and carrying out our functions.

 

  1. PURPOSE OF THE POLICY


3.1       The purpose of the Equality, Diversity and Inclusion Policy is to:

  • Give job applicants and employees confidence that they will be treated equitably and with dignity and respect
  • Set standards of behaviour expected of all employees
  • Support the Group to comply with its legal obligations
  • Create a supportive working environment free from discrimination, whereby employees are more productive
  • Attract a more diverse workforce bringing the benefits of a broader range of talent and improved decision making.
  • Better job retention

 

  1. POLICY IMPLEMENTATION

 

4.1       The  Group aims for an integrated approach to equality, diversity and inclusion throughout our dealings with stakeholders and consumers and throughout our employment practices, including recruitment, pay and conditions, appraisals, training, promotion, conduct at work, disciplinary and grievance procedures and termination of employment.  

4.2       The Group will embrace diverse thinking and foster a culture when every voice is welcome, heard and respected.

4.3       The Group will seek opportunities to take a pro-active stance in addressing inclusion. 

4.4       Every individual’s needs and preferences will be reflected as far as possible at everyday gatherings and events, including making these optional wherever possible.

4.5       Inclusive language and terminology will be used.

4.6       The Group will seek to take into account how individuals wish to be treated.

4.7       There will be regular training on equity, diversity and inclusion.

4.8       An Equality Impact Assessment will be carried out to ensure that equality diversity and inclusion is built into all policies, practices, procedures, processes, reviews and events.

 

4.9       Recruitment

 Recruitment, promotion and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. Shortlisting should be done by more than one person if possible.

Vacancies will be advertised to a diverse section of the labour market. Advertisements will avoid stereotyping and will use wording that encourages applications from all groups.

Job applicants will not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children.

Job applicants will not be asked about health or disability before a job offer is made, except in the very limited circumstances allowed by law: for example, to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability. Health or disability questions may be included in equal opportunities monitoring forms, which must not be used for selection or decision-making purposes.

The Group aims to have a workforce that as a minimum reflects the diversity of the communities within which it operates. Where protected characteristic groups are currently under-represented, the Group will aim to increase the diversity of applicants.

4.10      Agile working

 The Group offers a blend of office and home working to all its employees.

Part-time and fixed-term employees will be treated the same as comparable full-time or permanent employees and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.

The Group will consider opportunities to adjust contracted hours of work, on a temporary or permanent basis, where adjusted hours would be helpful in promoting equal employment opportunities, for example, where a member of staff is returning from maternity leave, or long-term sickness.  Working from home or part time hours will also be considered. Employees should refer to the relevant company policies for more information.

4.11     Providing for cultural and religious needs

The Group will seek to acknowledge and honour employees’ religious and cultural practices. In circumstances where an employee has a particular cultural or religious need which may conflict with existing work requirements, the Group will consider whether it is reasonably practicable to vary or adapt these requirements to enable such needs to be met. Where an employee requests either the accumulation of annual leave or unpaid leave in order to visit relatives overseas, sympathetic consideration will be given.

            If any employee wishes to take time off work for religious holidays additional to the English           public holidays, then annual leave should be requested. However, consideration will be given      to requests for unpaid leave, or exchanging English public holidays for other religious       holidays.

            The Group will sympathetically consider requests from employees who require short spells           out of the working day in order to pray. This can usually be accommodated through flexible         working. The Group will also consider requests for adjusted working day or hours during periods of fasting. 

4.12      Employment Terms

The Group will also ensure that there is no unlawful discrimination when it comes to offering pay and benefits, terms and conditions of employment, as well as training opportunities.

  1. RAISING CONCERNS

 5.1       The Group supports the right, and would encourage any employee, to raise any concerns if          they feel that: 

  • The organisation is not taking its responsibility to promote equality, diversity and inclusion seriously
  • This policy is not being applied fairly or consistently
  • Or the policy is at odds with the aims set out.

Equally, employees have the right to raise any concerns if they feel they have been unfairly           discriminated against in the application of any of the Group’s employment policies or procedures. To guard against issues like this the Group ensures all policies and procedures have an equality impact assessment.

Initially concerns should be raised informally where appropriate.  Issues will be taken seriously and resolved as quickly as possible. In some cases, depending on the situation, this may need to involve a third party.

Issues which cannot be resolved informally should be raised formally, in accordance with the Groups’ Grievance Procedure. Rights to be accompanied at meetings and/ or hearings are detailed in the Policy. For those employees whose first language is not English or who have an impairment or learning difficulty, expressing themselves formally may be difficult. In these circumstances, managers and HR will encourage individuals to seek help from a colleague.  Reasonable adjustments will be made, which may include assisting employees to formulate written evidence if they are unable to do so because of their impairment or other condition. In such circumstances, advice should be sought from the Head of Operations.

There may be cases where an individual makes an unfounded allegation of discrimination for malicious reasons. These cases will be investigated and dealt with fairly and objectively.

5.2       Disciplinary action

All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public.

The Group will take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities.

Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.

Sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.

It should not be assumed that any complaints or allegations arise out of over-sensitivity. Failure to undertake the responsibility of dealing appropriately with allegations of bullying, harassment, victimisation or unlawful discrimination may be regarded as a disciplinary offence.

  1. ROLES AND RESPONSIBILITIES

6.1       The Board of Directors has overall responsibility for the effective operation of this policy and for ensuring compliance with the relevant statutory framework. Day to day responsibility for operating this policy and ensuring its maintenance and review has been delegated to the Head of Operations reporting to the CEO on a regular basis.

6.2       The Board and CEO will:

  • Demonstrate the values of equality and fairness through their own behaviour
  • Take a lead role in ensuring that Equality, Diversity and Inclusion is embedded into all procurement, delivery of services and employment practices
  • Elect a member of the Board to Champion Equality, Diversity and Inclusion

6.3       The Head of Operations will:

  • Provide advice and guidance to staff and managers on the effective implementation of the employment elements of this policy
  • Ensure that all complaints and alleged breaches of this policy are dealt with seriously, sensitively, confidentially and in a timely manner

6.4       Line managers should:

  • Set a positive example by treating others with respect and setting standards of acceptable behaviour
  • Promote an inclusive working environment where unlawful discrimination is unacceptable and not tolerated
  • Ensure that their teams work effectively together
  • Should not discriminate unfairly within any area of employee management activity including recruitment, appraisal, selecting for training and other development opportunities, and in applying other Group employment policies and practices
  • Make employees aware of their responsibilities under this policy and should they become witness to, or aware of any breach, of this policy, that they must report it immediately to their line manager or the Head of Operations
  • Listen to employees’ concerns and take appropriate action

6.5       Staff will:

  • Take personal responsibility for behaving in a way that is supportive of and consistent with this policy, and therefore compliant with the Equality Act 2010
  • Help promote an inclusive environment by treating everyone with dignity and respect,
  • Respect and respond to the diverse needs of staff and others
  • Appropriately challenge and/ or report behaviour that may be considered to be offensive when directed against themselves or others
  • Take personal responsibility for ensuring that knowledge and skills on equality, diversity and inclusion issues are kept up to date.

 

EQUALITY IMPACT ASSESSMENT (‘EIA’)

 

  1. WHAT IS AN EQUALITY IMPACT ASSESSMENT (EIA)?


It is a tool to help us assess the likely effects of our policies and practices on people according to their protected characteristics, to ensure we don’t discriminate.  Discrimination is where someone is treated less favourably or put at a disadvantage because of their protected characteristics.  These are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex and sexual orientation.

Whilst the term policy is used, an EIA should be applied to any practice, procedure, strategy, plan, project, event or review.

An EIA also improves and promotes equality.

  1. WHEN SHOULD AN EIA BE CARRIED OUT?.

An EIA should form part of any new policy or practice and should be carried out whenever new policies and projects are being formulated or reviewed.  Procurement decisions, proposals to change services, event planning and business cases should all be subject to an EIA.  This is so that potential discrimination and opportunities to advance equality are identified at an early stage, to allow necessary amendments or enhancements.  However, not everything needs a full impact assessment, only policies and practices that are relevant to equality need to be put in focus.  A screening process should take place initially to establish whether the policy or practice could affect people because of one of the protected characteristics.  A template equality analysis form is included in this document.

If it is considered that there may be adverse impacts, a full impact assessment needs to be carried out.  If there is no potential for adverse differences then the initial assessment will be all that needs to be done, but a note should be made of this.

  1. THE QUESTIONS TO ASK


EIAs are based around four core questions, which are central to the process:

  • What is the purpose of the policy?

What it is meant to achieve.  The purpose needs to be defined in detail.

  • How is it seeking to achieve this?

How it works, with the full process to be considered.

  • Who benefits and how? (and who, therefore, doesn’t and why?)

This determines who gets the service or policy and highlights who doesn’t get what was intended and whether any disadvantages are created.

  • What are any ‘associated aims’?

As policies and practices affect other areas, this question is about identifying knock-on effects.

 

  1. INITIAL SCREENING


These are based on available evidence (including value judgements) and are more a pointer to      further action when necessary.  It is a short exercise that determines relevance.  Relevance is the potential for impact but not the impact itself and is to do with whether the policy or     practice affects people because of race, disability or gender, etc.

 

 

Positive impact

Negative impact

Neutral impact

Reasons and supporting evidence for impacts identified

Age

 

 

 

 

Disability

 

 

 

 

Gender Reassignment

 

 

 

 

Marriage/Civil Partnership

 

 

 

 

Pregnancy/Maternity

 

 

 

 

Race

 

 

 

 

Religious or beliefs

 

 

 

 

Sex (Gender)

 

 

 

 

Sexual Orientation

 

 

 

 

 

The degree to which a policy or practice affects someone will make it ‘high’, ‘medium’ or ‘low’ and it will need to be decided which of these bands a particular issue falls into.  Thought also needs to be given to distinguish between ‘major’ and ‘minor’ policies and practices, according to its importance to the organisation.  This should be taken into account when deciding if an EIA should be carried out.

If the policy or practice affects people because of protected characteristics it is likely that a full impact assessment is required. 

 

  1. FULL IMPACT ASSESSMENT


 If this is required: -

  • Record the name and job title of the individual carrying out the EIA
  • Is the responsibility of the policy or function shared with another organisation? If so, what responsibility and which bodies?
  • Consideration of whether the policy is likely to have an adverse impact, including direct or indirect discrimination and the reasons for this
  • Measure impact – via consultation or systems to be put in place to gather evidence
  • How the policy and resulting activities might affect different groups
  • How the policy might affect people vulnerable to discrimination in multiple areas of equality
  • Consider changes to the policy that will help reduce adverse impact on particular groups
  • Could any medium or low potential negative impact be minimised or removed?
  • If there’s no evidence that the policy promotes equal opportunity, could it be adapted?
  • Consider policy alternatives
  • Comparable policy examples that could help mitigate any adverse impacts
  • The potential of this policy to promote good relations between different groups
  • Decision on whether to adopt policy – summarise findings and describe any actions to be taken to address negative impacts.

 

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