Equal Opportunities Policy
The Company wholeheartedly supports the principle of equal opportunities in employment and opposes all forms of unlawful or unfair discrimination on the grounds of colour, race, nationality, ethnic or national origin, sex, age, marital status or disability. We believe that it is in the Company’s best interests, and those of all who work in it, to ensure that the human resources, talents and skills available throughout the community are considered when employment opportunities arise. To this end, we are committed, wherever practicable, to achieving and maintaining a workforce that broadly reflects the communities in which we operate.
Every possible step will be taken to ensure that individuals are treated equally and fairly and that decisions on recruitment, selection, training, promotion and career management are based solely on jobrelated criteria.
It is Company policy to fully comply with the Race Relations Act 1976 (as amended by the Race Relations (Amendment) Act 2000) and to observe the Commission For Racial Equality’s Code Of Practice For Employment.
The Managing Director is responsible for the Company’s Equal Opportunities Policy and its effective implementation.
Racial Equality
The Race Relations Act 1976 makes it unlawful to discriminate against a person, directly or indirectly, in
the field of employment.
It is the policy of the Company to ensure:
- That no job applicant or employee receives less favourable treatment than another on racial grounds;
- That no applicant or employee is placed at a disadvantage by requirements or conditions which have a disproportionately adverse effect on his or her racial group and which cannot be shown to be justifiable on other than racial grounds;
- That, where appropriate and where permissible under the Race Relations Act, employees of underrepresented racial groups are given training and encouragement to achieve equal opportunity within the Company;
- That guidance is provided for Management and Supervisory Staff to ensure that they understand their position both in law and Company policy;
- That existing procedures are examined and regularly reviewed to ensure changes are made when found to be potentially or unlawfully discriminatory;
- That a periodic survey of the workforce is undertaken to ensure that the Company’s Equal Opportunities Policy is applied.
Recruitment, Promotion, Transfer, Training And Dismissal
It is Company policy to ensure that it does not publish an advertisement that could reasonably be
interpreted as indicating an intention to discriminate against applicants from a particular racial group.
The Company does not:
- Confine advertisements unjustifiably to areas or publications that would exclude or disproportionately reduce the numbers of applications from a particular racial group;
- Specify such requirements as length of residence or experience in the UK, and where a particular qualification may be required, it is made clear that a fully comparable qualification obtained overseas is as acceptable as a UK qualification.
The Company endorses its commitment to equality of opportunity by including in literature sent to applicants a statement that it is an equal opportunities employer.
When recruiting through Agencies/Careers Offices/Schools et cetera the Company does not discriminate by indicating that certain groups will, or will not, be preferred or bring pressure on them to discriminate against members of a particular racial group.
The Company does not confine recruitment unjustifiably to those agencies/job centres/careers offices et cetera which, because of their particular source of applicants, provide only or mainly applicants of a particular racial group.
The Company does not recruit solely, or in the first instance, on recommendations of existing employees where the labour market is multi-racial, where this means only members of a particular racial group or disproportionately high racial group come forward.
The Company does not restrict access to opportunities for promotion or training in any way discriminatory.
Job and training vacancies are made known to all eligible employees.
Selection For Recruitment, Promotion, Transfer, Training And Dismissal
The Company does not discriminate or restrict access to arrangements made for recruitment, promotion,
transfer and training.
The Company does not directly or indirectly discriminate in selection criteria or tests and ensures that all requirements are job-related.
The Company will not require a standard of English higher than that needed for the safe and effective performance of the job or career pattern, or a higher level of education that is needed.
Overseas degrees, diplomas and other qualifications, which are comparable with UK qualifications, are accepted as equivalents and will not be deemed to be of an inferior quality.
Selection tests are not used which contain irrelevant questions or exercises on matters that may be unfamiliar to racial minorities e.g. general knowledge questions on matters more likely to be familiar to indigenous applicants. Any such selection tests are monitored to ensure they are job-related i.e. an individual’s test markings should measure ability to do or train for the job in question.
Management are required to treat all applicants equally, irrespective of their particular racial/ethnic origin. In addition, Management responsible for short listing, interviewing and selecting candidates are:
- Clearly informed of selection criteria and the need for their consistent application;
- Given guidance or training on the effects, which generalised assumptions and prejudices about race, can have on selection decisions;
- Made aware of the possible misunderstandings that can occur in interviews between persons of different cultural backgrounds.
In order to avoid direct or indirect discrimination the Company ensures that:
- Management responsible for selecting employees for transfer to other jobs are required to apply selection criteria without unlawful discrimination;
- Procedures relating to job transfers are periodically examined and amended if found to contain requirements or conditions that appear to be discriminatory, either directly or indirectly;
- Employees selected for training i.e. induction, promotion or skilled training are not subject to racial discrimination. In cases of dismissal, the Company does not discriminate on racial grounds or other grounds. The Company ensures that:
- Management responsible for selecting employees for dismissal or redundancy do not discriminate on racial grounds;
- Selection criteria for redundancies are closely examined to ensure that they are not discriminatory, either directly or indirectly.
Management responsible for conducting employee appraisals do not discriminate on racial grounds and assessment criteria is examined to ensure that there is no unlawful discrimination.
Terms Of Employment, Benefits, Facilities And Services
The Company does not discriminate on racial grounds in the provision of benefits, facilities and services
for employees and ensures that:
- All staff responsible for these aspects of employment follow this policy;
- The criteria governing eligibility for any benefits or services are examined to ascertain that they are not unlawfully discriminatory.
Grievance And Disciplinary Procedures
The Company does not discriminate in the operation of grievance and disciplinary procedures. It does not
ignore or treat lightly grievances from members of particular racial groups or presume them to be oversensitive
on discrimination matters.
In applying disciplinary procedures consideration will be given to the possible effect on an employee’s
behaviour due to the following circumstances:
- Racial abuse or other racial provocation;
- Communication and comprehension difficulties;
- Differences in cultural background or behaviour.
Cultural And Religious Needs
Although the Race Relations Act does not specifically cover religious discrimination, it would generally be
considered to be unlawful to discriminate where employees have particular cultural and religious needs
which conflict with existing work requirements, and where reasonably practicable, the Company will adapt
to meet such requirements.
Instructions And Pressure To Discriminate
The Company does not instruct or put pressure on others to discriminate on racial grounds.
Management shall not restrict the numbers of employees from a particular racial group in any particular work. Shop Stewards or other groups of workers may not induce the Company against recruiting members of particular racial groups i.e. by threatening industrial action, which is unlawful.
Deliberate instruction or pressure to discriminate will be treated as a disciplinary offence.
Victimisation
It is unlawful to victimise individuals who have made allegations or complaints of racial discrimination or
provided information about such discrimination, for example by disciplinary sanction or dismissal.
Guidance on this aspect of the law will be given by the Company Secretary to all employees, particularly those in positions of influence or authority.
Monitoring Equal Opportunity
The Company regularly monitors the effects of selection decisions, personnel practices and procedures in
order to ensure that equal opportunity is being achieved.
Periodic analysis is carried out on the ethnic composition of the workforce.
Selection decisions for recruitment, promotion, transfer and training are carefully monitored and analysed and reasons for the decisions made available. Where practicable, reasons for selection and rejection of applicants will be recorded at each stage of the selection process e.g. initial short listings and final decisions.
Responsibilities Of Individual Employees
Whilst the primary responsibility for providing equal opportunity rests with the Company, individual
employees at all levels, and of all racial groups also have responsibilities. Good race relations depend on
them, as much on Management. Their attitudes and activities are very important.
It is unlawful for individual employees to:
- Discriminate in the course of their employment against fellow employees or job applicants on racial grounds, e.g. in selection for recruitment decisions, promotion, transfer and training;
- Induce or attempt to induce other employees, unions or Management to practice unlawful discrimination, e.g. refusing to work with other employees from other racial groups;
- Victimise individuals who have made allegations or complaints of racial discrimination, or who have provided information about such discrimination.
To assist in the prevention of racial discrimination and promotion of equal opportunity individual employees will:
- Co-operate in measures introduced by Management designed to ensure equal opportunity and nondiscrimination;
- Draw the attention of Management to suspected discriminatory acts or practices
- Refrain from harassment or intimidation of other employees on racial grounds.
It should be recognised by individual employees from racial minorities that in many occupations advancement is dependent upon an appropriate standard of English.
The Elimination Of Discrimination
Employer’s Responsibility
The Company recognises its responsibility to ensure that there is no unlawful discrimination on the
grounds of sex, sexual orientation, race, colour, ethnic origin, disability, age or marriage and for the
promotion of equal opportunity in employment.
Employee’s Responsibility
Whilst the main responsibility for eliminating discrimination and providing equal opportunity is that of the
employer, individual employees at all levels have responsibilities too. They must not discriminate or
knowingly aid the Company to do so.
Recruitment
The Company does not discriminate directly or indirectly on the grounds of sex, sexual orientation, race,
colour, ethnic origin, disability, age or marriage in either:
- The arrangements made for deciding who should be offered a job;
- In any terms of employment;
- By refusing or omitting to offer a person employment.
The Company assesses each individual according to his or her personal capability to carry out a given job. It is not assumed that men or women only can perform certain kinds of work.
Age limits are retained only if they are necessary with regards to health and safety at work. The Company recognises that an unjustifiable age limit could constitute unlawful indirect discrimination for example, against women who have taken time out of employment to have children.
Genuine Occupational Qualifications
The Company recognises that it is unlawful to select candidates on the ground of sex except when
considerations of privacy and decency are involved.
The needs of a job for strength and stamina do not justify restricting employment to men.
Sources Of Recruitment
The Company does not discriminate:
- On the grounds of sex, age or marriage in the arrangements made for determining who should be offered employment whether recruiting by advertisements, through employment agencies, job centres or career offices;
- By implication that applications from one sex, age group or from married people will not be considered;
- By instructing or putting pressure on others not to consider for employment people of one sex, age group or married people;
- By publishing an advertisement that indicates, or might reasonably be understood to indicate an intention to unlawfully discriminate on grounds of sex, age or marriage.
Advertising
The Company advertises jobs in such a way as to encourage applications from suitable candidates of both
sexes. This is achieved both by wording of the advertisements and, for example, by placing
advertisements in publications likely to reach both sexes.
All advertising material and accompanying literature relating to employment or training matters are regularly reviewed to ensure it avoids presenting men and women in segregated jobs, which may discourage members of the opposite sex from applying for particular jobs.
Where vacancies can be filled from within the Company by promotion or transfer they are published in such a way that they do not restrict applications from either sex.
The Company does not recruit solely or primarily by word of mouth, which may restrict the choice of applicants available and prevent members of the opposite sex from applying.
Methods Of Selection
Where selection tests are used in recruitment they are specifically job-related and measure the applicant’s
actual or inherent suitability to undertake the job in question, or train for the work or career.
Such selection test are reviewed regularly to ensure that they remain relevant and free from any unjustifiable bias, either in content or scoring mechanism.
Dealing With Applications And Interviewing
The Company will ensure that:
- All managers responsible for recruitment are made aware of the provisions of the Sex Discrimination Act, including the fact that it is unlawful to instruct or put pressure on others to discriminate;
- Applications from both men and women, of all ages, are processed in the same manner and not segregated. All personnel responsible for handling applications and conducting interviews are given guidance on the avoidance of unlawful and indirect discrimination. Where practicable, records of interviews are kept which show why applicants were accepted or rejected;
- During interview proceedings questions are related to the requirements of the job. Questions about marriage plans or family intentions should not be asked as they may be construed as showing a bias against women. In order to assess whether personal circumstances will affect the performance of a job, i.e. unsocial hours or extensive travel to office or site, this subject should be discussed objectively without detailed questions based on assumptions about marital status and/or domestic obligations.
Promotion, Training And Transfer
The Company does not discriminate directly or indirectly on the grounds of sex, age or marriage in any
way that may restrict access to opportunities for promotion, transfer or training.
When undertaking employee reviews, the assessment criteria is not unlawfully discriminatory and the scheme is monitored by the Management to assess how it is working in practice.
Promotion and career development plans are reviewed regularly to ensure that traditional qualifications are justifiable requirements for the job to be done. Promotion is not necessarily based on the length of service that could be interpreted as unlawful indirect discrimination.
Where general ability and personal qualities are the main requirements for promotion candidates of both sexes with differing career patterns and general experience are considered.
Transfers and promotions are monitored to ensure no restrictions are made unjustifiably where employees are traditionally of one sex.
Company policy and practices regarding selection for training, day release and personal development are monitored to ensure there is no unlawful discrimination. The Company gives consideration for training and promotion to all age levels.
Health And Safety Legislation
Except where statutory provisions require men and women to be treated differently, e.g. Factories Act
1961 and Mines & Quarries Act 1954, the Company ensures that no distinctions are made between men
and women so far as is reasonably practicable, which includes specific health and safety requirements
under earlier legislation which are unaffected by the Health & Safety at Work Act.
It is Company policy to review and consider any significant differences in treatment brought to the attention of the Management. Terms And Conditions Of Employment And Staff Benefits And Services The Company regularly reviews all terms and conditions of employment, benefits and services to ensure there is no unlawful discrimination on the grounds of sex or marriage, for example:
- Part-time work, where required, is available to both male and female staff and pro-rata pay and benefits apply;
- Employee benefits are made available to both male and female employees whom are entitled to such benefits under Company policy.
Grievances, Disciplinary Procedures And Victimisation
The Company does not victimise an individual for any justifiable complaint, made in good faith, about sex,
age or marriage discrimination, or for giving evidence about such a complaint.
Any employee who, in good faith, seeks to take action under the Sex Discrimination Act or the Equal Pay Act, will not receive less favourable treatment than other employees and will not be subject to disciplinary action or dismissal.
The Company encourages employees to follow the procedures laid down in the Works and Staff Agreements, without prejudice to the individual’s right to apply to an Industrial Tribunal within the statutory time limit, i.e. three months beginning when the alleged act was committed or no time limit if the alleged victimisation is continuing.
Particular care is taken to deal effectively with all complaints of discrimination, victimisation or harassment under the Company’s Dignity at Work and Harassment Procedure.
Dismissals And Redundancies
The Company does not discriminate either directly or indirectly on the grounds of sex, age or marriage or
by treating an employee unfavourably in any other way.
Care is taken to ensure that members of one sex are not disciplined or dismissed for performance or behaviour which would be overlooked or condoned in the other sex.
Redundancy procedures affecting a group of employees, predominantly of one age group or sex, are carefully monitored to remove any effects, which might prove disproportionate and unjustifiable and/or lead to an imbalance in the remaining skills and experience in the Company. In the event of voluntary redundancy benefit for employees in the same circumstances, equal terms are offered to male and female employees.
In the event of change in the volume of business, it is found necessary for the Company to down-grade or introduce short-time working, or other measures, such arrangements will not unlawfully discriminate on the grounds of sex, age or marriage.
The Company takes all reasonably practicable steps to ensure that a high standard of conduct and behaviour is observed. Employees will not be intimidated, harassed or otherwise subjected to unfavourable treatment on the ground of their sex.
Retirement
The Company has a succession plan, which seeks to retain skills and knowledge that would otherwise be
lost through retirement.
The Company recognises that there is no national retirement age but fixes its retirement policy in line with the age at which State Pension becomes payable, currently age 65.
Whenever it meets the needs of the Company and is permitted under state legislation, employees may be able to draw their pension once they reach retirement age and continue to work if they choose.
The Company will consider phased retirement proposals from individuals who wish to scale-down their working-hours towards full retirement.