1.Policy Statement
IDS has developed a number of shared principles applicable to both management and colleagues to guide activities. The General Principles of Conduct and Action outline the core values by which all colleagues are expected to adhere during their employment.

The Principles of Conduct are professional commitment, respect for others, integrity, loyalty and solidarity. The Principles of Action are respect for the law, caring for the environment, worker health and safety and colleague rights.

These principles are embraced within the Equality and Diversity Policy, the IDS policy on Equal Opportunities. IDS expects that everyone should be treated with dignity and respect at work. In essence this means that all colleagues will be treated fairly and without bias particularly in terms of recruitment, training, promotion and career opportunities.

Equality of opportunity includes supporting the development of colleagues and avoids wasting their talents, creating a workplace where colleagues are confident of fair treatment, have access to opportunity and where the Company has a mechanism for solving any problems that occur.

IDS recognises that to focus on colleagues’ personal characteristics rather than their attributes is unfair, potentially unlawful, likely to lead to an adverse reputation in the
market and ultimately cause the business to operate below its full potential.

Links with other Company policy and procedure
From time to time this Policy refers to other Company policies which are available as follows:
• Grievance Procedure; colleagues who believe that they have been subject to unfair discrimination are advised to instigate the Grievance Procedure by registering a formal
written complaint (see “Equality & Diversity and Complaints” later in this Policy);
• Disciplinary Procedure; where a formal complaint results in disciplinary action managers are advised to follow the Disciplinary Procedure. Categories of people covered by the Equality & Diversity Policy
• colleagues of any category including full time, part time and those on paternity, maternity, sick or any other type of leave;
• other workers including those under the control of, but not necessarily employed by, the Company such as agency drivers and contractors;
• potential colleagues meaning a person who may be undergoing interview or assessment for employment;
• customers, suppliers, contractors, clients and any other category with whom the Company deals in the normal course of business;
• former colleagues.

The objectives of the Equality & Diversity Policy
• that no person will receive less favourable treatment or consideration on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy and
maternity, race, religion or belief, sex or sexual orientation;
• that no colleague (or potential colleague) will be disadvantaged by any terms and conditions of employment or Company policy, procedure or practice which cannot be
justified as necessary on operational grounds.

The importance of Equal Opportunities
Equal Opportunities are an integral part of good management practice intended to develop people to their full capacity for the benefit of the organisation and the individual. Equality of opportunity can lead to improved morale and a higher standard of business performance and greater competitive advantage.

The changing demographic profile of the UK and the composition of the working population mean that the Company is more likely to maximise its business potential if it uses available talent in the economy to the full regardless of the personal characteristics of colleagues.

Legal framework - Equality Act 2010 (effective from 1st October 2010)
A considerable amount of statutory legislation has evolved in recent years relevant to all types of discrimination. However, this is now consolidated in the Equality Act which is
effective from 1st October 2010. This Act harmonises and replaces previous discrimination legislation (e.g. the Race Relations Act 1976 and the Disability Discrimination Act 1995).

In addition, three Codes of Practice have been issued by the Equality and Human Rights Commission (EHRC) which deal with Employment, Equal Pay and Services, Public Functions
and Associations implications of the Act.

The three Codes are the authority by which Employment Tribunals will adjudicate on claims made under the Equality Act whilst a non-statutory (non-binding) Guide contains practical information and guidance. 

“Protected Characteristics”
The Equality Act protects people with “protected characteristics” from discriminatory treatment. These nine “protected characteristics” are age, disability, gender reassignment, race, religion or belief, sex, sexual orientation, marriage and civil partnership, pregnancy and maternity. Unless indicated otherwise, the types of discrimination described below apply to all “protected characteristics”.

2. Types of Discrimination

Direct discrimination
Direct discrimination occurs when someone is treated less favourably than another person because of a “protected characteristic”. The colleague does not actually have to be of
a “protected characteristic” to be a victim of direct discrimination (see paragraphs on Perceptive Discrimination and Associative Discrimination).

Indirect discrimination
Indirect discrimination is where an employer applies a condition, rule, policy or a practice which applies to everyone but particularly disadvantages or would disadvantage people
who share a “protected characteristic” (e.g. a requirement to work full time puts women at a greater disadvantage due to child care commitments). Indirect discrimination can be justified if the Company is able to show that it has acted reasonably. In particular, the discriminatory act must be “a proportionate means of achieving a legitimate aim.” A “legitimate aim” might be any lawful decision made in running the business or organisation. “Proportionate” means that it should be fair and reasonable in the circumstances including showing that the Company has considered “less discriminatory” alternatives to any decision made.

Discrimination arising from disability
Disabled colleagues are subject to an additional form of protection against discrimination arising as a consequence of their disability. As with indirect discrimination, this can be
justified if the treatment is a proportionate means of achieving a legitimate aim.

Duty to make reasonable adjustments
Employers are also under a duty to make reasonable adjustments to prevent disabled colleagues being put at a disadvantage by any condition, rule, policy, practice or physical
feature of its premises. This may include the provision of auxiliary aids where this is reasonable (e.g. by providing assistive technologies to help visually impaired staff use
computers effectively). 

Harassment
Harassment is defined as “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”. Colleagues are able to complain about behaviour which they find offensive even if it is
not directed at them and without the complainant possessing the relevant “protected characteristic” themselves. Colleagues are also protected from harassment because of “perception” and “association” (see relevant section below).

Bullying is a form of harassment and can take a wide range of forms. It may occur in isolation and may initially appear trivial but often accumulates and escalates. It can vary
from careless gossip, unsuitable remarks or jokes (inappropriate banter), deliberate exclusion, belittling or undermining behaviour to more serious behaviour such as malicious
comments, insulting and aggressive behaviour, threats, (verbal or physical) humiliation or unwanted sexual comments, suggestions, or advances.

Behaviour of this type is not necessarily confined to overt behaviour since it can also manifest itself in written form (e.g. e mails or by telephone) or other action which might disadvantage a colleague (e.g. creating a false impression which prevents career development or advancement). It is possible that behaviour will be perceived differently be the recipient when compared to how it was intended by another party. However, it is important to note that it is the interpretation of this behaviour by the recipient which is important. For example, a manager might deem his or her style to be firm whilst the colleague might deem it to be over -bearing and coercive.

Third party harassment
Third party harassment applies to sex, age, disability, gender reassignment, race, religion or belief and sexual orientation. Prior to 1 October 2013, under the Equality Act 2010, an
employer could be liable if an individual was harassed by a third party (for example, a client or supplier) during the course of employment, in circumstances where the employer
knew that the individual had been subjected to such harassment on at least two other occasions (whether by the same or a different third party) but the employer had failed to
take reasonably practicable steps to prevent it. 

The third-party harassment provisions were repealed with effect from 1 October 2013, as the Government considered that the provisions did not serve a practical purpose. Notwithstanding the repeal, the Company are committed to investigating all allegations of harassment and will take all reasonable steps to prevent harassment of colleagues.
Individuals should therefore raise concerns about any harassment from customers, suppliers or other third parties with their manager. 

Victimisation
Victimisation occurs when a colleague is treated badly because they have or, it is believed they have done or may do one or more of the following:
• made or supported (including giving evidence or information) a complaint;
• issued legal proceedings;
• raised a grievance;
• performed any other act for the purposes of or in connection with the Equality Act.
However, an individual is not protected from victimisation if they have made or supported a complaint maliciously.

Associative discrimination
Associative discrimination is a form of direct discrimination and/or harassment. It applies to race, religion or belief, sexual orientation, age, disability, gender reassignment and
sex. This is discrimination against a person because they associate with another person who possesses a “protected characteristic” (e.g. not promoting someone because they are
married to a Christian).

Perceptive discrimination
Perceptive discrimination is also a form of direct discrimination and/or harassment. It applies to race, religion or belief, sexual orientation, age, disability, gender reassignment
and sex. This is discrimination against someone because others think they possess a particular “protected characteristic”. It applies even if the person does not actually possess
that characteristic (e.g. subjecting a heterosexual colleague to homosexual banter because they are thought to be gay)

3. “Protected Characteristics”: Summary of key points

• Age
• Disability
• Gender Reassignment
• Marriage and Civil Partnership
• Pregnancy and Maternity
• Race
• Religion or Belief
• Sex
• Sexual Orientation

Age
The Equality Act 2010 protects people of all ages. It comes as no surprise therefore that is unlawful (for example) to discriminate against job applicants or colleagues because of their age.

Disability
The definition of disability under the Act is a person who has “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”. Other key points relating to disability include:
• As outlined above the Company has a duty to make “reasonable adjustments” for colleagues to help them overcome any substantial disadvantage in the workplace arising
from a disability and must not subject them to unfavourable treatment arising from their disability;
• Discrimination arising from a disability and/or a failure to make reasonable adjustments can only occur where the employer or other person acting for the employer knows, or
could reasonably be expected to know that the person has a disability;
• Indirect discrimination also covers disabled people. This means that a job applicant or colleague could claim that a particular policy, practice or procedure disadvantages people
with the same disability (unless justifiable);
• The Act makes it unlawful, except in certain circumstances, for the Company to ask about a candidate’s health prior to offering employment. However, the Company requests
colleagues to complete a health questionnaire after an offer of employment is made (a policy which is compliant with the Equality Act) so that we can see if we need to provide
any support or adjustments for the colleague joining the business.

Gender reassignment
Gender Reassignment is a way of describing an individual’s transition. To undergo gender reassignment usually means to undergo some sort of medical intervention, but it can also
mean changing names, pronouns, dressing differently and living in their self-identified gender. Gender Reassignment is a protected characteristic under the Equality Act.

The Act also protects a woman (for example) who decides to live permanently as a man without actually undergoing any medical procedures. Colleagues are only protected if they
intend to live permanently in the gender opposite to their birth sex. It is discrimination to treat transsexual individuals less favourably for being absent from work because they propose to undergo, are undergoing or have undergone, gender reassignment than they would be treated if they were absent because they were ill orinjured. Medical procedures for gender reassignment, such as hormone treatment, shouldnot be treated as a ‘lifestyle’ choice.

Marriage and civil partnership
The Act continues to protect colleagues who are married or in a civil partnership againstdiscrimination. However, single people are not protected.

Pregnancy and maternity
A woman is protected against discrimination on the grounds of pregnancy and maternity during the period of her pregnancy and any statutory maternity leave to which she is
entitled. This includes protection from unfavourable treatment because of illness suffered as a result of her pregnancy, and/or because she is on maternity leave because she is
exercising (or seeking to exercise), or has exercised (or sought to exercise) the right to ordinary or additional maternity leave. An employer should therefore not take into account a colleague’s period of absence due to pregnancy-related illness when making a decision about employment. Any colleague whose role becomes redundant during maternity leave is entitled to be offered any suitable vacancy that is available at the relevant time.

Race
The Equality Act continues to define ‘race’ to include colour, nationality and ethnic or national origins. A racial group can be made up of two or more different racial groups (e.g.
Black Britons).

Religion or belief
The Equality Act defines religion to include any religion and also a lack of religion. This means that colleagues or jobseekers are protected if they do not follow a certain religion or
have no religion at all. A religion must have a clear structure and “belief” which means any religious or philosophical belief and includes a lack of such belief. The “belief” must affect the colleague’s life choices and the way they live. Denominations or sects within a religion can be considered a protected religion or religious belief. Humanism is also a protected philosophical belief however political beliefs are not protected under the Equality Act. Discrimination due to religion or belief can occur even where both the discriminator and
recipient are of the same religion or belief.

Sex
Both men and women are protected under the Equality Act as they have been under previous sex discrimination legislation.

Sexual orientation
The Equality Act protects bisexual, homosexual and heterosexual people in the same way as previous legislation protected this group.

Occupational Requirement (OR)
It may be lawful (under limited circumstance) to discriminate in jobs where a “protected characteristic” (e.g. sex, race) is an “Occupational Requirement” (OR). For example, if the
job needs to be held by one particular sex for reasons of privacy or decency or for reasons of authenticity. However, in view of the type of business that SG operates an OR is unlikely to apply to most activities.

Employer Liability
The Company is responsible for acts of discrimination committed by colleagues and workers during the course of employment whether they were committed with or without the
employers’ knowledge or approval. Other relevant features of the Company’s liability in this regard include:
• Acts which may be committed outside the workplace while representing the Company or attending a Company function (e.g. inappropriate acts committed at a Christmas party);
• It is also unlawful for the Company to instruct or attempt to instruct any other person to discriminate (e.g. instructing a colleague to serve only white people)
• Note; While the Company may be held legally liable for an act of discrimination this does not absolve the colleague/worker of responsibility and can lead to their personal prosecution. If the individual concerned is a colleague, they will be subject to the Company’s disciplinary procedure where appropriate. This may result in dismissal depending on the circumstances and seriousness of the case

4. Responsibility for the application of the Equality & Diversity Policy
As well as management, all colleagues and workers share responsibility for applying this Policy in the workplace. Colleagues and workers are reminded that they should bring to the attention of their manager or their HR Team if they observe any discriminatory behaviour. Such matters will be fully investigated and appropriate action taken to eradicate the behaviour and prevent its occurrence in the future.

Colleagues who believe that they have been subject to unfair discrimination are advised to follow the Company’s Grievance Procedure. Managers and supervisors have particular responsibility to ensure that they adhere to the principles of the Equality & Diversity Policy when recruiting, selecting, training, developing and promoting colleagues.

5. Equality, Diversity and IDS employment practice

The following principles relate to colleagues and potential colleagues:

Recruitment
• Every applicant for vacancies which are advertised will be given equal consideration
• The most suitable people will be selected for jobs with regard only to their experience, skills, attributes and qualifications
• No one will be unfairly discriminated against, directly or indirectly, on the grounds of any “protected characteristic” (except for justified operational grounds)
• The Company will only use employment agencies who adhere to the principles of this Policy Advertising
• Efforts will be made to ensure that job advertisements are published so as to be available to all areas of community
• Advertising material (e.g. websites, journals) will avoid stereotypical assumptions about job applicants
• Job titles and job content will be clear, free from bias and will not discourage any applicant or disadvantage any individual from any group who may possess a “protected characteristic”

Selection
• Application forms ask only for information relevant to the applicant’ s ability to carry out the job
• Candidates are assessed and selected against objective criteria relevant to the specific job
• Selection decisions will be free from bias and not based on assumptions or prejudice
• During interview candidates will only be asked questions relevant to the job, their previous experience, skills, qualifications and attributes
• Selection processes should enable disabled applicants to be considered on a like for like basis with non-disabled applicants. The Company should consider making reasonable adjustments to the working environment to enable a disabled person to consider a particular opportunity including adjustments to allow disabled applicants to attend job interviews or selection events
• The Company should consider suitably qualified oversees applicants on an equal basis to their UK equivalent and avoid their automatic exclusion when considering candidates
against key job requirements (subject to Immigration policy/legislation)
• Selection tests (where used) should be free from any unjustifiable bias, either in content or scoring mechanism and should be relevant to the job for which the applicant has applied
• In accordance with the Equality Act medical information will only be requested after a job offer has been made and obtained for both disabled and non-disabled applicants

Induction
• Colleagues should be briefed on the Equality & Diversity Policy during their induction Training and Development
• Training and development opportunities will be open to all suitably qualified and experienced colleagues regardless of whether a colleague possess “protected characteristics”
• Promotional opportunities will be open to all suitably qualified and experienced colleagues

Terms and Conditions of Employment

• All colleagues will be treated without bias with respect to pay, benefits and other terms and conditions of employment, having regard to local or geographical benchmarks,
skills, attributes and experience. Terms of employment will be determined by reference to the job regardless of whether a colleague possesses “protected” characteristics
• Salary reviews and performance appraisals will be carried out for all colleagues in accordance with Company Policy regardless of whether they possess “protected characteristics”

Termination of Employment
• The Company will not terminate a colleague’s employment due to any “protected
characteristic”
• It may be necessary to terminate a colleague’s employment due to their ill health and this may be linked to a disability. However, all reasonable adjustment/alternative  employment opportunities should be considered prior to termination of employment
• An individual’s “protected characteristics” will not influence redundancy selection decisions
• Former colleagues will not be subject to discrimination or unlawful victimisation in relation to any reference provided by the Company

6. Equal Opportunities Policy and Complaints

Colleagues who believe they have been subject to unfair discrimination (including victimisation, bullying or harassment), are advised to follow the Company’s Grievance
Procedure.

The following principles are key components of the complaints procedure:
• All complaints will be treated seriously and dealt with promptly, fairly and objectively
• The sensitive nature of discrimination complaints is recognised and any investigations will be dealt with confidentially with information disclosed to necessary parties only
• The Company reserves the right to separate complainant and alleged discriminator pending investigation where appropriate (temporary transfer usually of the discriminator)
to another department or site
• The Company reserves the right to suspend a colleague/worker who is suspected of discrimination on basic pay pending investigation
• Following an investigation, it may be necessary to invoke disciplinary action. Unfair discrimination is regarded as a serious breach of Company policy and in some cases may
be regarded as gross misconduct resulting in summary dismissal
• All colleagues/workers are reminded that making a false or malicious complaint of discrimination will in itself be regarded as a serious disciplinary offence
• Informal remedies may be sought to resolve complaints in appropriate circumstances
• The Company owes a duty of care to provide a safe place and system of work. If a complaint is sufficiently serious the Company may be obliged to investigate even where
this is against the complainant’s wishes

7. Summary

The Company recognises the positive business benefits arising from the diverse contribution of all colleagues and seeks to harness individual ability in a way that allows personal fulfilment as well as meeting organisational needs. The Company will not condone discriminatory behaviour and will take all appropriate steps to ensure it is dealt with and to
work towards its future eradication.

Managers are advised to preside over fair, consistent and non-discriminatory practices in their workplaces and encourage an environment in which colleagues are treated with dignity, respect and free from any form of harassment, bullying or victimisation. Monitoring and vigilance of workplaces by managers will help prevent its occurrence in the first place and limit its impact through early intervention. Managers should avoid ignoring signs that unacceptable behaviour may be occurring and deal with it promptly and  proportionately.

8. Further advice on the Equality & Diversity Policy

Please contact your HR Team for further guidance.

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