Barclay Simpson’s Equality, Diversity and Inclusion Policy

Barclay Simpson embraces equality, diversity and inclusion and will seek to promote their benefits in all business activities. We will further develop our business culture to encourage, value, and manage that belief. We seek to widen the media in which we recruit to ensure as diverse an employee and candidate base as possible. We strive to make sure that our clients meet their own equality and diversity targets.

We endeavour to eliminate discrimination and encourage diversity amongst our own workforce. Our aim is that our employees will be truly representative of all sections of society and each person feels respected and able to give their best.

Barclay Simpson does not discriminate against its employees on the basis of gender, sexual orientation, marital or civil partner status, gender identity, race, colour, nationality, ethnic or national origin, religion or belief, pregnancy, disability or age (the further protected characteristics).

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.

The Directors are responsible for this policy and any necessary training on equal opportunities. Managers must set an appropriate standard of behaviour, lead by example, and ensure that those they manage adhere to the policy and promote our aims and objectives with regard to equal opportunities.

This policy covers all employees, officers, consultants, contractors, casual and agency workers. It does not form part of your contract of employment and we may amend it at any time.

What is discrimination?

You must not unlawfully discriminate against or harass other people including current and former employees, job applicants, clients, candidates, suppliers, and visitors. This applies in the workplace, outside the workplace (when dealing with clients, candidates, suppliers, or other work-related contacts), and on work-related trips or events including social events.

The following forms of discrimination are prohibited under this policy and are unlawful:

• Direct discrimination: treating someone less favourably because of a protected characteristic. For example, rejecting a job applicant because of their race, gender, or age because they would not ‘fit in’ would be direct discrimination.
• Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular protected characteristic more than others and is not justified.
• 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.
• Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.
• Disability discrimination: this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability. Direct discrimination can also be committed where the treatment is “because of” a protected characteristic the individual is perceived to have or because of the characteristic of another person, such as someone with whom the claimant associates (e.g., discrimination against a colleague because he/she has a disabled child or because you perceive that individual has a particular sexual orientation or gender preference).

How will this policy be implemented?

• Advertising: job advertisements should avoid stereotyping or using wording that may discourage particular groups from applying.
• Monitoring: to ensure the policy is working effectively with respect to recruitment and selection, the Company may monitor job applicants’ racial group, gender, disability, and age as part of the recruitment procedure. Provision of this information is voluntary and will not adversely affect an individual’s chances of recruitment or any other decision related to their employment. We will maintain records of this data (in an anonymised format) as part of the HR system solely for the purposes stated in this policy.
• Recruitment and selection: we aim to recruit the best person for the job. Candidates are sourced and interviewed fairly, objectively and without bias.
• Questions about health and disability: applicants should not be asked about health or disability before a job offer is made. There are limited exceptions, for example where questions are necessary to establish if an applicant can perform an intrinsic part of the job (subject to reasonable adjustments) or to establish if an applicant is fit to attend an assessment or needs adjustments to be made during the interview process. If in doubt seek advice before relying on an exception.
• Terms and conditions of employment: our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all employees who should have access to them and that there are no unlawful obstacles to accessing them.
• Promotion and career development: we seek to give all employees the opportunity for planned training and development. Career progression decisions will be made on the basis of merit and capability.
• Grievance and disciplinary policies: we aim to apply these policies consistently to all employees, any individual differences that could lead to misunderstanding in considering incidents under these policies will be recognised.
• Disability: the requirements of candidates and employees who are disabled or develop a disability (as defined under the relevant legislation) will be reviewed to ensure that whenever possible reasonable adjustments are made to enable them to enter into or remain in employment with Barclay Simpson. Promotion opportunities, benefits and facilities for disabled employees will not be unreasonably limited and every reasonable effort will be made to ensure that disabled employees participate fully in the workplace. Where there are circumstances which mean that it will not be reasonable for us to accommodate suggested adjustments, we will explain our reasons and try and find an alternative solution where possible.
• Part-time workers: we will monitor the conditions of service for part-time employees and their progression within the Company to ensure that they are being offered appropriate access to benefits, training and promotion opportunities.
• Requests to alter working hours will be given serious consideration by the Company.
• Training: training and resources will be provided to enable managers, supervisors and other employees to implement and uphold the provisions of this policy.

What happens if this policy is breached?

If you believe that you have been discriminated against, or you have witnessed behaviour which you believe amounts to discrimination; you should first bring this to the attention of your line manager or the HR Manager. You may also raise the matter through the grievance procedure.

If you believe that you may have been harassed related to a protected characteristic you should consult the Anti- Harassment & Bullying Policy on the intranet.

Anyone who makes such an allegation in good faith will not be treated less favourably or victimised as a result. False allegations of a breach of this policy which are found to have been made in bad faith will be dealt with under our disciplinary procedure.

Any employee who is found to have committed an act of discrimination or harassment will be subject to disciplinary action. Such behaviour may constitute gross misconduct and may result in summary dismissal. The Company will always take a strict approach to serious breaches of this policy.

This policy will be monitored and reviewed at least every two years or following changes in relevant legislation.

Approved by the Board of Directors

Ian Coyle, Chairman

28/01/2022