1. Introduction

Qualco UK Ltd (“the Company”) is committed to achieving a working environment which provides equality of opportunity and freedom from unlawful discrimination on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation. This Policy aims to remove unfair and discriminatory practices within the Company and to encourage full contribution from its diverse community. We are committed to actively opposing all forms of discrimination and to promote a workplace culture where everyone is treated fairly. Our suppliers are expected to commit to the same standards.

Qualco aims to provide a service that does not discriminate against its clients in the means by which they can access the services supplied by the Company. Qualco believes that all employees, contractors, clients and service providers are entitled to be treated with respect and dignity.

2. Objectives of this Policy

2.1 To prevent, reduce and stop all forms of unlawful discrimination in line with the Equality Act 2010 and in conjunction with the Disability Discrimination Act of 1995.

http://www.legislation.gov.uk/ukpga/1995/50/contents

2.2 To ensure that recruitment, promotion, training, development, assessment, benefits, pay, terms and conditions of employment, redundancy and dismissals are determined on the basis of capability, qualifications, experience, skills and productivity.

2.3 All employees are responsible for the promotion of this Policy, led by Senior Management.

3. Designated Officer

Name: Jane Maher
Position: Head of HR
Telephone Number: 07545 427104

4. Definition of Discrimination

Discrimination is unequal or differential treatment which leads to one person being treated more or less favourably than others are, or would be, treated in the same or similar circumstances on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.

Discrimination may be direct or indirect, and includes discrimination by perception and association.

5. Types of Discrimination

5.1 Direct Discrimination

This occurs when a person or a policy intentionally treats a person less favourably than another on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.

5.2 Indirect Discrimination

This is the application of a policy, criterion or practice which the employer applies to all employees but which is such that:

• It is it detrimental to a considerably larger proportion of people from the group that the person the employer is applying it to represents;
• The employer cannot justify the need for the application of the policy on a neutral basis; and
• The person to whom the employer is applying it suffers detriment from the application of the policy.

Example: A requirement that all employees must be 6ft tall if that requirement is not justified by the position would indirectly discriminate against employees of certain ethnic origin, as they are less likely to be able to fulfil this requirement.

5.3 Harassment

This occurs when a person is subjected to unwanted conduct that has the purpose or effect of violating their dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

5.4 Victimisation

This occurs when a person is treated less favourably because they have bought or intend to bring proceedings or they have given or intend to give evidence.

6. Unlawful Reasons for Discrimination

6.1 Sex

It is not permissible to treat a person less favourably on the grounds of sex, marital status, civil partnership, pregnancy or maternity, gender reassignment or transgender status. This applies to men, women and those undergoing or intending to undergo gender reassignment. Sexual harassment of men and women can be found to constitute sex discrimination.

Example: Asking a woman during an interview if she is planning to have any (more) children constitutes discrimination on the ground of gender.

6.2 Age

It is not permissible to treat a person less favourably because of their age. This applies to people of all ages. This does not currently apply to the calculation of redundancy payments.

6.3 Disability

It is not permissible to treat a disabled person less favourably than a non-disabled person. Reasonable adjustments must be made to give the disabled person as much access to any services and ability to be employed, trained, or promoted as a non-disabled person.

6.4 Race

It is not permissible to treat a person less favourably because of their race, the colour of their skin, their nationality or their ethnic origin.

6.5 Sexual Orientation

It is not permissible to treat a person less favourably because of their sexual orientation. For example, an employer cannot refuse to employ a person because s/he is homosexual, heterosexual or bisexual.

6.6 Religion or Belief

It is not permissible to treat a person less favourably because of their religious beliefs or their religion or their lack of any religion or belief.

It is Qualco's policy to endeavour, on request, to alter an employee's working pattern so that breaks can be granted at times that coincide with his/her needs for religious observance. Alternatively, the employer will, where appropriate, endeavour to grant employees reasonable time off during working hours for religious observance insofar as this is possible and practicable, considering the needs of the business and whether or not such arrangements might cause disturbance or disruption to other members of staff and/or their work or work patterns.

However, where an employee requests time off at a particularly busy time or at a time when the employee's absence would otherwise cause difficulties for the business or his/her department, or where the amount of time off requested is unreasonable or excessive (considering the needs of the business), the employer reserves the right to refuse to grant some or all of any of the time off requested. The Employee must request time off by discussing with HR (hr@qualco.co.uk)

All employees, whatever their religion or belief, will be treated equally in respect of requests for time off for religious observance or requests for alterations to their working patterns for religious reasons.

In addition, employees on a voluntary basis may disclose their religion or belief so that any religious needs can be assessed by HR, and fair consideration given to what facilities and arrangements Qualco might reasonably provide for staff. While no employee is obliged to disclose his/her religion, belief or religious practices to the employer, employees are encouraged to do so for this reason.

7. Positive Action in Recruitment

Under the Equality Act 2010, positive action in recruitment and promotion applies as of 6 April 2011. ‘Positive action’ means the steps that the Company can take to encourage people from groups with different needs or with a past record of disadvantage or low participation, to apply for positions within the Company.

If the Company chooses to utilise positive action in recruitment, this will not be used to treat people with a protected characteristic more favourably, it will be used only in tie-break situations, when there are two candidates of equal merit applying for the same position.

8. Reasonable Adjustments

The Company has a duty to make reasonable adjustments to facilitate the employment of a disabled person. These may include:

8.1 Making adjustments to premises;

8.2 Re-allocating some or all of a disabled employee’s duties;

8.3 Transferring a disabled employee to a role better suited to their disability;

8.4 Relocating a disabled employee to a more suitable office;

8.5 Giving a disabled employee time off work for medical treatment or rehabilitation;

8.6 Providing training or mentoring for a disabled employee;

8.7 Supplying or modifying equipment, instruction and training manuals for disabled employees; or

8.8 Any other adjustments that the Company considers reasonable and necessary provided such adjustments are within the financial means of the Company.

If an employee has a disability and feels that any such adjustments could be made by the Company, they should contact the Designated Officer.

9. Responsibility for the Implementation of this Policy

All employees, contractors and agents of the Company are required to act in a way that does not subject any other employees or clients to direct or indirect discrimination, harassment or victimisation on the grounds of their race, sex, pregnancy or maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.

The co-operation of all employees is essential for the success of this Policy.

Senior employees are expected to follow this Policy and to aim to ensure that all employees, subcontractors and agents do the same.

Employees may be held independently and individually liable for their discriminatory acts by the Company and in some circumstances an Employment Tribunal may order them to pay compensation to the person who has suffered as a result of discriminatory acts.

The Company takes responsibility for achieving the objectives of this Policy, and endeavours to ensure compliance with relevant Legislation and Codes of Practice.

10. Acting on Discriminatory Behaviour

If an employee is the subject or perpetrator of, or witness to, discriminatory behaviour this will be dealt with according to the company’s disciplinary and grievance procedure.

11. Advice and Support on Discrimination

Equality and Human Rights Commission
Arndale House
The Arndale Centre
Manchester
M4 3AQ

3 More London
Riverside Tooley Street
London
SE1 2RG

Telephone (England): 0845 604 6610
Website: www.equalityhumanrights.com

Citizens Advice Bureau
Myddleton House
115-123 Pentonville Road
London
N1 9LZ

Website: www.citizensadvice.org.uk

12. The Extent of the Policy

12.1 The Company seeks to apply this Policy in the recruitment, selection, training, appraisal, development and promotion of all employees. Adherence to the Policy extends to Company suppliers.

12.2 Qualco will review this Policy and share with employees annually along with mandatory on-line training.

12.3 Qualco will commit to auditing its policies and practices to ensure diversity and inclusion is part of our workplace culture and operations. Our Policy and practices will be benchmarked against best practice.

This policy has been approved & authorised by:

Name: Christian Jacob
Position: Managing Director
Date: February 2024