Equal Opportunities & Behaviour Policy & Procedure

Policy Statement

The Company stands by the principles of equality and fair treatment for Employees, Workers, candidates and Clients both within and outside of the workplace environment. The person responsible for reviewing, training and updating the policy is the Operations Director. A review happens at least annually in January and is supported by our external HR consultant.

We understand the importance of having a robust approach to equal opportunities in all that we do for our Clients; from taking details of vacancies, interviewing candidates and throughout the recruitment process up to and following placements.

We operate a diversity monitoring and reporting system that complies with best practice and enables the Company to eliminate discrimination and encourage diversity amongst its workforce and within our candidate database. We treat job applicants and Employees equally, regardless of age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; and sexual orientation. These are called protected characteristics. Every Employee has a personal responsibility to ensure that the Policy is adhered to.

We operate a thorough training process for all new employees through our Equal Opportunities and Diversity workshop. Supporting training documents are provided through our Intranet and updates in policy are communicated through quarterly meetings to all employees.

The Company is committed to complying with relevant equality legislation and codes of practice as a minimum benchmark. Wherever possible the Company strives to exceed legislative requirements by developing policies and procedures that help it achieve its aim of being an Employer and Recruiter of Choice.

This Policy applies to the advertisement of jobs, our internal recruitment process and recruitment on behalf of our Clients, training, development and promotion, conditions of work, pay and benefits and to every other aspect of employment.

We expect our supply chain to comply with all relevant equality legislation and if they are found to be non-compliant will cease to be an approved supplier.

Equal Opportunities Procedure

Discrimination:

A. The Company will not discriminate either directly or indirectly because of a protected characteristic.

B. Direct discrimination is when an individual is treated less favourably than another individual because of a protected characteristic. Indirect discrimination is applying a requirement or condition which, although applied equally to all persons, particularly disadvantages those who share a protected characteristic.

C. Indirect discrimination is applying a requirement or condition which, although applied equally to all persons, particularly disadvantages those who share a protected characteristic.

D. Discrimination by perception is direct discrimination against an individual because others think they possess a particular protected characteristic.

E. Associative discrimination is direct discrimination against an individual because they associate with another individual who possesses a protected characteristic

F. All of our Consultants and Employees involved in recruitment (in particular) should request training if they have any doubt about how to apply this Policy.

G. Any instance of doubt about the application of this Policy, or any other questions regarding discrimination, should be addressed to the Operations Director in the first instance.

Disability:

A. Employees and candidates who are disabled or become disabled in the course of their employment or whilst seeking work through our Company should inform the [Operations Director] who will seek external advice if necessary to ensure that the correct level of support is provided. An individual is disabled if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities.

B. Employees and candidates with disabilities may also wish to advise the Company of any "reasonable adjustments" to their employment or working conditions which they consider will be necessary or which they consider would assist them in the performance of their duties or their performance for prospective employers.

C. Careful consideration will be given to any proposals of this nature and, where reason- able and practicable, such adjustments will be made. There may however be circumstances where it will not be reasonable or practicable for the Company or a Client to accommodate those proposals and where less favourable treatment may be justified in accordance with the statutory provisions.

Discrimination Complaints

• Any candidate or client may use the Company’s Complaint Procedure to complain about discriminatory conduct. The Company will ensure that they feel able to raise such complaints and no individual will be penalised for raising a complaint of this nature.

• If a complaint about discriminatory conduct is found to be untrue and made in bad faith, this matter will be fully investigated.

Bullying & Harassment:

A. The Company believes that all Employees have a right to be treated with dignity. Any Employee who harasses any other Employee will, after a full investigation, be subject to the Company’s Disciplinary Procedure. In serious cases, such behaviour may be deemed to constitute Gross Misconduct and may result in Summary Dismissal.

B. Harassment is 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.

C. Victimisation occurs when an individual is treated badly because they have made or supported a complaint or raised a grievance, or because they are suspected of doing so.

D. Bullying is offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power which is meant to undermine, humiliate or injure the person on the receiving end. Examples of bullying would include picking on someone or setting him or her up to fail or making threats or comments about someone’s job security without good reason.

The following behaviour at work or in the course of employment is unacceptable:

• Derogatory remarks

• Insensitive jokes or pranks

• Insulting or aggressive behaviour

• Ignoring or excluding an individual

• Public criticism of a colleague

This list is not exhaustive. The actions listed above must be viewed in terms of the distress they may cause the individual. It is the perceptions of the recipient that determine whether any action or statement can be viewed as behaviour that may constitute bullying or harassment.

Any complaint of bullying or harassment received will be investigated to ensure the problem is resolved as quickly as possible. The Employee making the complaint may do so informally or formally, via the Grievance Procedure.

All allegations of harassment will be dealt with seriously, promptly and in confidence. Employees who feel they have been subject to harassment must not hesitate in using this procedure nor fear victimisation. Retaliation against an Employee who brings a complaint of harassment is a serious disciplinary offence which may constitute gross misconduct and lead to dismissal.

Any member of Management will provide, in confidence, advice and assistance to Employees subjected to harassment and assist in the resolution of any problems, whether through informal or formal means.

Informal Procedure:

A. If an incident occurs which an Employee thinks may be harassment and they do not wish it to happen again, they may prefer initially to attempt to resolve the problem informally. In some cases it may be possible and sufficient to explain clearly to the person engaging in the unwanted conduct that the behaviour in question is not welcome, that it offends them or makes them uncomfortable and that it interferes with their work. The Employee should make it clear that they want the behaviour to stop. In circumstances where this is too difficult or embarrassing for them to do on their own, they should seek support from a friend at work or a member of Management.

B. If the Employee is in any doubt as to whether an incident or series of incidents which have occurred constitute harassment, then in the first instance they should approach a member of Management on an informal basis. He or she will be able to advise them as to whether the complaint necessitates further action, in which case the matter will be dealt with formally/informally as appropriate. If the conduct continues or if it is not appropriate to resolve the problem informally, it should be raised through the following formal process.

Formal Procedure:

A. Where informal methods fail, or serious harassment occurs, the Employee is advised to complain formally to the Operations Director. Consideration will be given to the immediate separation of the complainant and the alleged harasser where possible. In serious cases the alleged harasser may be suspended.

B. The Employee will be interviewed by the Operations Director handling the complaint to establish full details of what happened. He or she will then carry out a thorough, impartial and objective investigation as quickly as possible. Those carrying out the investigation will not be connected with the allegation in any way. An investigation will be carried out quickly, sensitively and with due respect for the rights of both the Employee and the alleged harasser.

C. The investigation will involve interviews with the person against whom the Employee is making the complaint. The alleged harasser will be given full details of the nature of the complaint and will be given the opportunity to respond.

D. The Employee and the alleged harasser will have the right to be accompanied and/or represented by a colleague or union representative at any interviews. The Employee will not be asked to provide details of the allegations repeatedly unless this is essential for the investigation.

E. Strict confidentiality will be maintained throughout the investigation into the allegation. Where it is necessary to interview witnesses, the importance of confidentiality will be emphasised to them.

F. When the investigation has been completed the Employee will be informed whether or not their allegation is considered to be well founded. If the allegation is well founded, disciplinary action may be taken against the person alleged to have committed the behaviour the Employee is complaining about and, depending on the circumstances and the seriousness of the complaint, may result in the dismissal of that person.

G. If the allegation is not well founded, consideration will be given where possible as to whether it is necessary to transfer or reschedule the work of both or either party in cases where it would not be appropriate for either of them to continue to work in close proximity to each other.

H. The Company takes these matters very seriously. However, malicious complaints of harassment can have a serious and detrimental effect upon a colleague. Any unwarranted allegation of harassment, made in bad faith, will be deemed potential gross misconduct. We are sure that all Employees appreciate that this must be so, to protect the integrity of this Policy.

Behaviour Policy

You are expected at all times to maintain a responsible and disciplined attitude to your work, your colleagues and anyone with whom you come into contact during the course of your duties. You are required to maintain good timekeeping standards in accordance with your hours of work. Persistent lateness and unacceptable levels of absence and/or unauthorised absence will be dealt with in accordance with the Company’s Disciplinary Procedure.

The Company prides itself in conducting business with integrity and in a professional and honourable way. The Company expects you to conduct yourself properly at all times and not to bring discredit on the Company. This includes normal workplace activities and also extends to activities outside work depending on their nature and whether you are representing the organisation.

The Company expects you to comply with all reasonable directions and duties in connection with your employment.

Failure to comply with any of the personal conduct requirements may result in disciplinary action being taken and may lead to dismissal.

Drugs and Alcohol

A. The Company expects its Employees to attend work in a fit and appropriate state with no impairment from the effects of alcohol or drugs or other substances (that may affect conduct or performance) for non-medical purposes. Incapability through alcohol, drugs or solvents or other substances or being in possession of drugs, or other substances unless prescribed by a doctor is regarded as gross misconduct and may result in summary dismissal.

B. Employees who misuse drugs or alcohol or other substances may have their judgement, safety awareness and work performance adversely affected. Any such Employees put themselves at risk and can also be a danger to their colleagues, customers and members of the general public. The Company has a statutory duty under the Health and Safety at Work Act 1974 (as amended) to ensure the health and safety at work of all its Employees. Employees attending work in these circumstances additionally put the Company at risk commercially and may bring it into disrepute.

C. The Company does not allow the consumption, storage, transportation, promotion, possession, distribution or sale of illegal drugs or other substances (i.e. those subject to control under the Misuse of Drugs Act 1971) in any office or premises under the control of the Company. This is a criminal offence, which will be reported to the appropriate authority and may lead to prosecution. The Company regards an offence of this nature as gross misconduct and this will lead to dismissal.

D. Any Employee taking prescription drugs which may impair performance or judgement and/or conduct are required to inform their immediate supervisor/manager. Failure to do so may be treated as drugs abuse and may be dealt with under the Company Disciplinary Procedure.

E. The Company is committed to assisting Employees who bring to its attention their dependency on alcohol or drugs or other substances and who are prepared to seek treatment to overcome the dependency.

F. The Company reserves the right to redeploy into a suitable alternative post or, if no such post is available, to suspend with pay whilst medical opinion is sought, any Employee undergoing treatment whose normal duties are safety critical or commercially sensitive.

G. Where Employees are authorised to entertain Clients or to attend social events with or in the presence of Clients or suppliers, the Company expects Employees to conduct themselves appropriately at all times.

H. If the Company has reasonable grounds to believe that you are under the influence of drugs, alcohol or other substances at work you will not be paid for this day.

I. The Company reserves the right to carry out random drug, substances and alcohol screening tests on Employees in the workplace. If an Employee receives a positive test result this will be viewed as potential Gross Misconduct and will render the Employee liable to summary dismissal. Refusal to submit to a drug, substances (or alcohol) screening test without reasonable excuse will be dealt with through the Company’s Disciplinary Procedure.

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