Equal Opportunities Policy

This is a policy statement setting out the company’s position on equality in the workplace. This document is
not contractual but describes the way the company is committed to equality and equal opportunities, and
how it will implement that commitment.

The company is committed to the principles of equality in employment and to fostering a workplace where
all employees can prosper and advance based on the suitability and quality of their work alone.
This policy is based on the principle that all employees should be treated with dignity and respect. There
should be no unfair discrimination of employees, workers or associates of the company based on gender, race, ethnicity, nationality, health, age, sexual orientation, marital status, religious belief or
philosophical belief.

The company seeks to ensure that this policy is implemented in practice in all and every aspect of the
business and its activities. The policy is supported by all senior management and all employees are
encouraged to read it and abide by it. The company will take all reasonable steps to ensure that all
decisions relating to recruitment, training, promotion, opportunities, provision of benefits and selection are
made based on objective and job-related criteria alone.

The company will take all reasonable steps to ensure that any stakeholders and contractors comply with
this policy.

All employees, workers and associates of the company are asked to read this policy and are expected to
comply with the provisions at all times.

LEGISLATION

There are several pieces of legislation making provision for equal opportunities and the company will
always comply with the relevant law as required. However, the company is committed to exceeding the
minimum expected standards for equal opportunities wherever possible.
The company will review and update this policy in line with any changes to the relevant legislation.

DISCRIMINATION

The company is opposed to all unfair and unjustified discrimination. Discrimination is defined by the
Equalities Act 2010 and can take the form of direct or indirect discrimination, harassment and victimisation.
It is unlawful to discriminate against a person on the grounds of the following ‘protected characteristics’
Gender Race,
ethnicity and nationality,
Disability Age
Sexual orientation
Marital status
Religious or philosophical belief
Gender Reassignment
Pregnancy and Maternity

RESPONSIBILITIES

Directors / Partners

The directors/partners of the company have collective responsibility for the content, implementation and
review of this policy. They are also responsible for leading by example in matters of equality and diversity
and encouraging good practice across the organisation.

HR leader

The director or manager with day-to-day responsibility for HR matters is required to ensure this policy is
distributed to all employees and operatives. They shall also ensure managers have received equal
opportunities for training and that the provisions of the policy are implemented on a day-to-day basis.

Contract managers, site managers and supervisors

All employees who have line management responsibilities shall ensure that those employees and
operatives under their control comply with the requirements of this policy. They shall ensure that any
breaches of the policy are investigated, recorded and, where necessary, formal disciplinary action taken.
Where in doubt, the matter should be referred to the HR leader or a director.

Employees and operatives

All employees, agency workers and contract labourers are required to comply in all respects with the
provisions of this policy. Where an employee is subject to or witnesses a breach of this policy they should
report the matter without delay to his/her line manager, or where not appropriate, the HR leader or a
director.

1. IMPLEMENTATION OF OUR COMMITMENT TO EQUAL OPPORTUNITIES

This policy applies to:
1. Recruitment and Selection
2. Training and Development
3. Appraisal, Promotion and Transfers
4. Terms of Employment, Benefits and Facilities
5. Grievance and Disciplinary Procedures
6. Dismissals, Restructuring and Redundancies
Recruitment and Selection

All vacancies will be advertised internally and will be made accessible to all employees, including those
on maternity, paternity or adoption leave. However, in circumstances of restructuring or redundancy, it may
be necessary to ring-fence available vacancies for those employees whose positions are at risk.

All recruitment decisions will be based on fair and objective criteria. The company will not make
assumptions that only certain types of people will be able to perform certain types of work. Any decision
will be made based on an individual’s suitability to perform the role.
All selection tests will be job-specific and should be devised to test an individual’s suitability to perform that
particular role.

The company will take all reasonable steps to remove barriers to the recruitment process or employment,
where these may disadvantage applicants who have a certain protected characteristic. This may include
making recruitment materials available in alternative formats, making adjustments to recruitment
assessments and making sure that vacancies are advertised in the local community in a manner that is
visible to all demographic groups.

Where an applicant has a disability and believes that they will be disadvantaged by the company
recruitment process they should make the company aware of this as soon as possible so that the
company can make reasonable adjustments to the process to remove that
disadvantage.

The company will seek to ensure that those persons who make decisions on recruitment have read and
understood this policy and where possible received relevant training on the principles of equal
opportunities.

Training and Development

The company will reflect its commitment to equal opportunities through equality of access to training and
career development opportunities.

The availability of training and development opportunities will be determined by business needs, an
employee’s ability and the availability of suitable training courses.

All internal training and development programs will be designed to comply with the provisions of this policy
and to ensure that they do not discriminate against or prejudice employees who have a particular protected
characteristic.

Appraisal, Promotion and Transfers

All appraisal processes and criteria will be devised to ensure that they are compliant and consistent with
the provisions of this policy.

An employee’s appraisal results should be based on individual merit, performance and ability. Appraisal
results will be reviewed where there is evidence that opportunities for training, promotion and transfer are
being offered disproportionately to one group of employees.

Opportunities for promotion or transfer will be offered to employees based on the individual’s ability
and suitability for the new role only.

The company will seek to eliminate or reduce the impact of any provision, criterion or practice relating to
appraisal, promotion or transfer, which indirectly puts employees of a particular protected characteristic at a
disadvantage.

Terms of Employment, Benefits and Facilities

The company will ensure that the terms of employment, benefits and access to facilities available to
employees are provided in a way which is not unlawfully discriminatory.

In particular, part-time and/or fixed-term employees will receive the same terms (pro-rata where
appropriate) of employment, benefits and access to facilities as full-time and/or permanent employees.
Any discrepancy in rates of pay, benefits, bonuses or commission will be dependent on an employee’s ability
and merit only.

The company is legally obliged to make reasonable adjustments for employees who have a disability and
to consider requests for flexible working conditions from certain employees and therefore it may be
necessary, to comply with those obligations, to offer terms of employment or facilities to those
employees which are preferential. To do so will not be in breach of the company’s commitment to equal
opportunities, but rather is a manifestation of that commitment.

Pay and bonus criteria will be developed and reviewed to ensure that they do not disadvantage employees
who has a particular protected characteristic?

Grievance and Disciplinary Procedures

An employee will not be disciplined, dismissed or otherwise subjected to less favourable treatment for
raising, in good faith, a grievance complaining of a breach of this policy, or otherwise making a complaint
about equal opportunities and discrimination. Likewise, if an employee assists another person, in
good faith, with such a grievance they will not be subjected to disciplinary procedures.

Employees are also directed to the company Whistle Blowing Policy where they believe in good faith that a
member or associate of the company is acting in an unlawfully discriminatory manner.

No employee having a particular protected characteristic will be disciplined or dismissed for conduct or
performance for which a person who did not have that particular protected characteristic would not be
disciplined or dismissed unless there is a genuine and lawful justification for different treatment.

Dismissals, Restructuring and Redundancies

Redundancy and restructuring processes will be developed to ensure that they are not in themselves
unlawfully discriminatory.

The company will take all reasonably practicable steps to ensure that those employees responsible for
administering restructuring and redundancy processes do not apply the relevant criteria in a way which it is
unlawfully discriminatory.

The company will review its redundancy and restructuring procedures and criteria where there is evidence
that it is prejudicing employees who have a particular protected characteristic.

DISABILITY POLICY

The company will, wherever possible, seek to make adjustments to accommodate issues relating to any
employee’s health, regardless of whether or not they have a disability.

The company is committed to making available to employees who have a disability the same opportunities
for recruitment, training, development and promotion. The company is aware of and committed to,
complying with its duty to make reasonable adjustments where a physical feature of the workplace, a
provision, or circumstances puts a disabled employee at a substantial disadvantage. The company will
provide auxiliary aids to a disabled employee where necessary and reasonable and will make any further
adjustments which are reasonable and which would reduce or negate the substantial disadvantage
suffered.

The company will take into account the impact of any disability on an employee’s conduct, performance
and attendance when assessing those matters.

The company will seek to consult with an employee about any matter upon which his / her disability
will have an impact and employees are encouraged to bring to the attention of their designated manager or
other appropriate manager any concerns or issues arising in the workplace as a result of the disability.

FAMILY-FRIENDLY POLICY

The company is committed to providing terms and conditions of employment that are compatible with an
employee’s family commitments.

The company therefore encourages employees who have children or the responsibility for the upbringing
of a child to use the company’s flexible working policy which supports their statutory right to flexible working.
Employees are also directed to the company policies which cover leave and pay in circumstances of
maternity, paternity and adoption.

SUBCONTRACTOR ORGANISATIONS

It is a requirement of the company that all subcontractor organisations, that employ one or more members
of staff, have in place a suitable equal opportunities policy and they agree to comply with the company’s commitment to equality and diversity.