IMSL Equality and Diversity Policy
Introduction
Intelligence Management Support Services Limited (IMSL) is committed to promoting and maintaining equality and diversity and to the prevention of discrimination and/or harassment in relation to all aspects of our business.
This policy sets out the organisation’s obligations in relation to equality and diversity and how we intend to fulfil those obligations and promote and maintain equality of opportunity and diversity in everything we do. In doing so, we intend to meet the expectations of our learners, employees and all other third parties that have dealings with the organisation.
This policy will be made available to learners at induction and suppliers and any other relevant third party upon request. If requested we can provide this policy in large print format, in electronic form or in translation.
Monitoring and review
The organisation will monitor the implementation of this policy on an ongoing basis to ensure that the principles and procedures set out in it are being effectively implemented by the practice and in any event a formal monitoring process shall be carried out and recorded in accordance with paragraph 5 below. The organisation has appointed Laura Bailey, Director to be responsible for the operation of the policy.
The policy will be reviewed annually with careful consideration given as to whether all of our business activities over the preceding 12 months were compliant with it, including monitoring of the ethnic and gender composition of existing staff and applicants for jobs and the number of people with disabilities within these groups. We will give due regard to any complaints or expressions of dissatisfaction with regard to any issue covered by this policy and to any circumstances where the organisation has identified shortcomings in its implementation of this policy. We will implement any changes where required in accordance with the results shown by the monitoring process where our resources allow.
We will review this policy on an ongoing basis to reflect changes in the law and guidance issued from time to time by the Education & Skills Funding Agency and any other relevant body and best practice (having regard to the resources available to us). In any event this policy will be reviewed at least annually.
Key principles
IMSL is committed to avoiding discrimination in its dealings with learners, employees both full-time and part-time, directors and all other third parties that have dealings with the organisation and to promoting diversity in all its professional activities.
Everyone at the organisation is expected and required to treat all others equally and with the same attention, courtesy and respect regardless of their:
- race or racial group (including colour, nationality and ethnic or national origins);
- sex;
- sexual orientation, whether actual or perceived;
- religion or belief;
- age, whether actual or perceived;
- disability;
- gender reassignment;
- marriage and civil partnership; or
- pregnancy and maternity.
The types of action that are against the organisation’s policy are:
Direct discrimination, where a person is, without lawful cause, less favourably treated on any of the above grounds.
Indirect discrimination, where a requirement or condition that cannot be justified is applied equally to all groups but has a disproportionately adverse effect on members of one particular group by reason of any of the above grounds. Indirect discrimination can occur whether intentional or not.
Victimisation, where someone is treated less favourably than others because he or she has complained or taken action against the organisation for unlawful discrimination on one or more of the above grounds or has assisted another person to do so.
Harassment, which occurs when unwanted conduct on one of the above grounds has the purpose or effect of violating another person’s dignity or creating a hostile, degrading, humiliating or offensive environment for that person. Such behaviour can involve physical acts or verbal and non-verbal communications and gestures. It can consist of a series of minor acts or comments or a one-off act of sufficient severity.
Discrimination by perception, where people are believed to have one or more of the characteristics which may lead to discrimination
Discrimination by Association, where the person discriminated against does not have the characteristics leading to discrimination, but someone associated with them does have those characteristics or is perceived to have those characteristics
In addition, the organisation will ensure that nobody with whom it has dealings will suffer any substantial disadvantage arising from any disability that they might have. The organisation is committed to making reasonable adjustments for those with a disability in relation to job opportunities, promotion and training within the organisation and the provision of services to learners.
All the areas of discrimination set out above are collectively referred to as “the above grounds” in the rest of this policy.
Implementation of this policy
IMSL will implement the key principles set out above in the following ways:
The organisation will observe the key principles in accepting instructions from and all its dealings with learners and third parties;
The organisation is generally free to decide whether to accept instructions from any particular client but any refusal to act must not be based on any of the above grounds and care must be taken to avoid there being any perception that they apply.
Any requests by disabled learners (or any third party) for reasonable adjustments to be made in the light of their disability will be considered and wherever possible acted upon e.g. by visiting learners at their own premises, providing information in large print or on audio cassette tape.
In any circumstances where staff or any third parties are to be instructed, they will be instructed solely on the basis of their skill, experience and suitability (having regard to issues such as specialist expertise and cost) to undertake the work in question.
All suppliers of services or products to the organisation will be selected only on the basis of their suitability to supply such services or products and selection will not be discriminatory having regard to any of the above grounds.
The organisation will take steps to ensure that its suppliers of services and products and all third parties from whom it commissions services or products, are committed to the principles of equality and diversity set out in this policy.
The organisation’s terms of business will state our commitment to meeting the needs of all of its learners. The terms of business and the organisation’s complaints policy and any other external policy will be supplied in large print format, on audio cassette tape or in translation upon request.
Training sessions will be arranged for all personnel on this topic including further training where appropriate. This policy forms part of the organisation’s induction programme.
The management of the organisation will consider any future developments of the organisation’s strategic and business planning, or changes to the office manual, to ensure that no inadvertent breach of this policy occurs.
The organisation is committed to providing equal opportunities in employment. All job applicants, employees, director/directors will receive equal treatment in relation to the above grounds. It is good business sense for the organisation to ensure that its staff are used in a fair and effective way. All employees will be given appropriate access to training and all promotion decisions will be made solely on the basis of merit.
Redundancy criteria and procedures will be monitored to ensure that they are fair and objective and do not directly or indirectly discriminate against any employees and disciplinary procedures will be similarly monitored.
Although it is unlawful to discriminate in favour of certain groups on the grounds of race or sex, positive action to enable greater representation of under-represented groups is permitted by law and the appropriateness of such action will be kept under review. For example, we will take steps to
ensure that knowledge of vacancies reaches a wide labour market. Job selection criteria will be reviewed regularly to ensure that they are justifiable on non-discriminatory grounds. We will also monitor applicants’ gender, ethnicity, religion, disability etc and use the data acquired to consider whether further steps should be taken to ensure compliance with this policy.
The organisation will endeavour to accommodate the requirements of employees religious, cultural and domestic obligations.
If an employee is disabled or becomes disabled in the course of their employment, the organisation encourages them to discuss with their head of department or with the client services director any reasonable adjustments to their working conditions which they consider necessary, or which would assist in the performance of their duties. Careful consideration will be given to any such proposals, including consultation with medical advisors, and they will be accommodated wherever possible and proportionate to the needs of the job. Nevertheless, there may be circumstances where it will not be reasonable for the organisation to accommodate the suggested adjustments in which case we will provide the employee with reasons for refusal.
Recruitment and selection
We aim to ensure that no job applicant suffers discrimination because of any of the protected characteristics above.
Job advertisements should avoid stereotyping or using wording that may discourage groups with a particular protected characteristic from applying.
We take steps to ensure that our vacancies are advertised to a diverse labour market. Where appropriate, the IMSL Director may approve the use of lawful exemptions to recruit someone with a particular protected characteristic.
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 the IMSL Director. For example:
Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).
Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment.
Positive action to recruit disabled persons.
Equal opportunities monitoring (which will not form part of the decision-making process).
Applicants should not be asked about past or current pregnancy or future intentions related to pregnancy. Applicants should not be asked about matters concerning age, race, religion or belief, sexual orientation, or gender reassignment without the approval of IMSL Director (who should first consider whether such matters are relevant and may lawfully be taken into account).
We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such
as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from the UK Border Agency.
To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in our organisation, we monitor applicants’ ethnic group, gender, disability, sexual orientation, religion and age as part of the recruitment procedure.
Fixed-term employees and agency workers
Fixed-term employees and agency workers will be offered appropriate access to benefits, training, promotion and permanent employment opportunities. We will, where relevant, monitor their progress to ensure that they are accessing permanent vacancies.
Part-time work
Part-time employees will be offered appropriate access to benefits and training and promotion opportunities. We will ensure requests to alter working hours are dealt with appropriately.
Enforcement and complaints
IMSL is committed to the principles set out in this policy and their effective implementation and will do its best to resolve any complaints relating to any of the issues covered by this policy.
Everyone should be aware that any breach of this policy is a potential risk to the practice, as well as a possible professional offence. We are not insured against the consequences of any illegal breach and liability for any breach may attach not only to the individual(s) concerned but also to the owners of the organisation. In any event, any claims in this regard will involve the organisation in significant commitment of managerial time.
For that reason, any breach is likely to be regarded as a serious disciplinary offence. If any employee is concerned that a breach of this policy may be occurring or has a complaint that they have been the victim of a breach, they should immediately report this to their head of department or to the client services director.
Any client who considers that we have breached this policy should address their complaint to the IMSL Director who will advise the complainant of the procedures to follow. Where possible, complaints should be made in writing, but IMSL will consider complaints made orally in circumstances where, by reason of a disability, any person would be disadvantaged by having to make a complaint in writing.
IMSL will also make any other reasonable adjustment to its complaints procedure to make the process accessible to persons with a disability.
