Clipper is committed to promoting equal opportunities in employment. All colleagues and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics).
About this policy
1.1 This policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.
1.2 This policy covers all colleagues, officers, consultants, contractors, volunteers, casual workers and agency workers.
1.3 This policy does not form part of any colleague’s contract of employment and we may amend it at any time.
1. Who is responsible for this policy?
1.1.1 The Board has overall responsibility for the effective operation of this policy and for ensuring compliance with discrimination law.
1.1.2 All managers must set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy.
1.1.3 If you are involved in management or recruitment, or if you have any questions about this policy, you should contact the HR team to request training or further information.
1.1.4 All individuals are responsible for adhering to the principles set out in this policy and promoting our aims and objectives regarding equal opportunities.
1.2 Discrimination
1.2.1 You must not unlawfully discriminate against or harass other people including current and former colleagues, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts or when wearing a Clipper uniform), and on work-related trips or events, including social events.
1.2.2 The following forms of discrimination are unlawful:
1.2.2.1 Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.
1.2.2.2 Indirect discrimination: a provision, criterion or practice that applies to everyone but negatively affects people with a particular Protected Characteristic more than others, and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally do more childcare than men. Such a requirement would be discriminatory unless it can be justified.
1.2.2.3 Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti-harassment and Bullying Policy.
1.2.2.4 Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.
1.3 Recruitment and selection
1.3.1 Recruitment, promotion, and redundancy selection will be conducted on the basis of merit, using objective criteria and without discrimination. Shortlisting should be done by more than one person and with the involvement of HR. Our recruitment procedures should be reviewed regularly to ensure that individuals are treated fairly on the basis of their merits and abilities.
1.3.2 Vacancies should generally be advertised widely. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. Wording should also not discriminate e.g. advert for a role that would say looking for a young and lively individual.
1.3.3 We take steps to ensure that our vacancies are advertised to a diverse labour market.
1.3.4 Job applicants should 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, whether they are flexible or have a family that put constraints on them.
1.3.5 Job applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with the approval of HR. For example:
1.3.5.1 Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).
1.3.5.2 Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment.
1.3.5.3 Positive action to recruit disabled persons.
1.3.5.4 Equal opportunities monitoring (which will not form part of the selection or decision-making process).
1.3.6 Where necessary, job offers can be made conditional on a satisfactory medical check.
1.3.7 We are required by law to ensure that all colleagues are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective colleagues, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation.
1.3.8 To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in Clipper, we may monitor applicants’ ethnic group, gender, disability, sexual orientation, religion and age as part of the recruitment procedure. Providing this information is voluntary, and it will not affect anyone’s chances of recruitment or any other decision related to their employment. The information is removed from applications before shortlisting, and kept in an anonymised format. Analysing this data helps us avoid discrimination and improve equality and diversity.
1.4 Training and promotion and conditions of service
1.4.1 Training needs will be identified through regular appraisals. You will be given appropriate access to training to enable you to progress within the organisation and all promotion decisions will be made on the basis of merit.
1.4.2 Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all of you who should have access to them and that there are no unlawful obstacles to accessing them.
1.5 Termination of employment
1.5.1 We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.
1.5.2 Disciplinary procedures and penalties will be applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.
1.6 Disabilities
1.6.1 If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate.
1.6.2 If you experience difficulties at work because of your disability, you may wish to contact your manager or HR to discuss any reasonable adjustments that would help overcome or minimise the difficulty. They may wish to consult with you and/or a medical adviser about possible reasonable adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable we will explain our reasons and try to find an alternative solution where possible.
1.6.3 We will monitor the physical features of our premises to consider whether they might place anyone with a disability at a substantial disadvantage. Where necessary, we will take reasonable steps to improve access.
1.7 Part-time and fixed-term work
1.7.1 Part-time and fixed-term staff should be treated the same as comparable full-time or permanent staff and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.
1.8 Breaches of this policy
1.8.1 We take a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure. Serious cases of deliberate discrimination may amount to gross misconduct, resulting in dismissal.
1.8.2 If you believe that you have suffered discrimination, you can raise the matter through our Grievance Procedure or through our Anti-harassment and Bullying Policy as appropriate. Complaints will be treated in confidence and investigated as appropriate.
1.8.3 There must be no victimisation or retaliation against staff who complain about discrimination. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our Disciplinary Procedure.
1.9 Related policies
1.9.1 This policy is supported by the following other policies and procedures:
1.9.1.1 Anti-Harassment and Bullying Policy;
1.9.1.2 Grievance Procedure;
1.9.1.3 Disciplinary Procedure;
1.9.1.4 Flexible Working Procedure;
1.9.1.5 Maternity, Paternity, Adoption and Shared Parental Leave Policies;
1.9.1.6 Parental Leave Policy;
1.9.1.7 Social Media Policy;
1.9.1.8 Time Off for Dependants Policy;
1.9.1.9 Dress Code.
