Equal Opportunities and Non-Discrimination Policy

1. Policy Statement

1. We do not discriminate against employees on the basis of their gender, sexual orientation, marital or civil partner status, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability or age. The principle of non-discrimination and equality of opportunity applies equally to the treatment of former employees, visitors, clients, customers and suppliers by members of our current workforce.
2. The measures we take to implement the principle of non-discrimination have been devised on the basis of advice published by the relevant governmental and professional bodies. We are committed to a programme of action to make this policy effective and to bring it to the attention of all employees.
3. This policy deals with the specific categories of employees and areas of work which we have identified as potentially giving rise to equal opportunities issues and provides more specific guidance on the parameters of our policy and approach to equal opportunities.
4. All employees have a duty to act in accordance with this policy, and therefore to treat colleagues with dignity at all times, and not to discriminate against or harass other members of staff, whether junior or senior to them. We will not tolerate any discriminatory practices or behaviour.

2. Scope and purpose of the policy

1. This policy applies to the advertising of jobs and recruitment and selection, training and development, opportunities for promotion, conditions of service, benefits and facilities and pay, health and safety and conduct at work, grievance and disciplinary procedures and termination of employment, including redundancy.
2. We will take appropriate steps to accommodate the requirements of employees' religions, cultures, and domestic responsibilities.

3. Forms of discrimination

1. Discrimination may be direct or indirect and it may occur intentionally or unintentionally.
2. Direct discrimination occurs where someone is put at a disadvantage for a reason related to one or more of the grounds set out in paragraph 1a above. For example, rejecting an applicant on the grounds of their race because it is considered they would not "fit in" could be direct discrimination.
3. Indirect discrimination occurs where an individual is subject to an unjustified provision, criterion or practice which puts them at a particular disadvantage because of, for instance, their sex or race. For example, a height requirement would be likely to eliminate proportionately more women than men. If this criterion cannot be objectively justified for a reason unconnected with sex, it would be indirectly discriminatory on the grounds of sex.
4. Discrimination also includes victimisation (less favourable treatment because of action taken to assert legal rights against discrimination, or to assist a colleague in that regard) and harassment (which is dealt with under our Anti-Harassment and Bullying Policy).

4. Recruitment and selection

1. We seek to ensure that no job applicant receives less favourable treatment on any of the unlawful grounds listed in paragraph 1a above. Our recruitment procedures are reviewed regularly and are intended to criteria are regularly reviewed to ensure that they are essential for the effective performance of the job and therefore justified on non-discriminatory grounds.
2. We take steps to ensure that knowledge of vacancies reaches a wide labour market and, where relevant, groups underrepresented in our organisation. Vacancy advertisements  include an appropriate short statement on our Equal Opportunities and non-Discrimination Policy and a copy of this policy is made available to those who enquire about vacancies.

5. Employee training and promotion and conditions of service

1. Employee training needs are identified through regular appraisals. All employees will be given appropriate access to training to enable them to progress within the organisation and all promotion decisions will be made on the basis of merit.
2. The composition and movement of employees at different levels are regularly monitored to ensure equality of opportunity at all levels of the organisation. Where appropriate, steps will be taken to identify and remove unnecessary or unjustifiable barriers and to provide appropriate facilities and conditions of service to meet the special needs of disadvantaged or under-represented groups.
3. Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all employees who should have access to them and that there are no unlawful obstacles to accessing them.

6. Termination of employment

1. We monitor redundancy criteria and procedures to ensure that they are fair and objective and are not directly or indirectly discriminatory.
2. We also ensure that disciplinary procedures are carried out fairly and uniformly for all employees, whether they result in the giving of disciplinary warnings, dismissal or other disciplinary action.

7. Disability discrimination

1. If you are disabled, or become disabled, you are encouraged to tell us about your condition. This is to enable us to support you as much as possible within the context of any health and safety implications for you or your colleagues. You may also wish to advise your line manager or the CFO of any reasonable adjustments to your working conditions or the duties of your job which you consider to be necessary, or which would assist you in the performance of your duties. Your line manager or the CFO may wish to consult with you and with your medical adviser(s) about possible reasonable adjustments. Careful consideration will be given to any such proposals and they will be accommodated where possible and proportionate to the needs of your job. Nevertheless, there may be circumstances where it will not be reasonable for us to accommodate suggested adjustments and in such cases we will ensure that we provide you with information as to the basis of our decision not to make any adjustments.
2. We will monitor the physical features of our premises to consider whether they place disabled workers, job applicants or service users at a substantial disadvantage compared to other employees. Where possible and proportionate, we will take steps to improve access for disabled employees and service users.

8. Fixed-term employees and agency workers

We monitor our use of fixed-term employees and agency workers, and their conditions of service, to ensure that they are being offered appropriate access to benefits, training, promotion and permanent employment opportunities. We will, where relevant, monitor their progress to ensure that they are accessing permanent vacancies.

9. Part-time employees

We monitor the conditions of service of part-time employees and their progression to ensure that they are being offered appropriate access to benefits and training and promotion opportunities. We will ensure requests to alter working hours are dealt with appropriately.

10. Breaches of the policy

1. If you believe that you may have been discriminated against you are encouraged to raise the matter through our Grievance Procedure. If you believe that you may have been subject to harassment you are encouraged to raise the matter through our Anti-Harassment and non- Discrimination Policy. If you are uncertain which applies to you or need advice on how to proceed you should contact our CFO.
2. Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure. Employees who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations which are found to have been made in bad faith will, however, be dealt with under our Disciplinary Procedure.
3. To make a complaint of discrimination, harassment, victimisation or unfair treatment, you should provide:
   1. the name of the person who is alleged to have carried out the discrimination;
   2. details of what form of discrimination has occurred, and when and where the occurrence(s) took place;
   3. the names of any witnesses to incidents of discrimination;
   4. the names of any others who have been treated in a similar way;
   5. any action already taken by the employee to counteract the discrimination;
   6. a preference for a solution.

   Following on from receipt of a complaint under this procedure, we will fully investigate the complaint. In instances of sexual or racial harassment, your anonymity will, as far as possible, be protected. You should also keep the matter confidential.

4. Any employee who is found to have committed acts of discrimination or harassment will be subject to disciplinary action. Serious instances of such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. We always take a strict approach to serious breaches of this policy.

CSEONDP 10/2025